Perspectives

The three exits from accidental American status examined honestly: streamlined compliance, renunciation at the new $450 fee with the dedicated relief procedures, and the narrow case where waiting is defensible.

Three discharges, an assessment rule reported in the tables, a ground the court raises of its own motion: what the case law changes for the reassessed SASU director.

France's Prime Minister has announced a voluntary disclosure window for 2027. Ten years after the STDR, should taxpayers wait or act now? Our analysis.

The framework article of the France-US Tax Desk: ten structural mismatches between the two systems, why competent national advisers still produce failures, and the single-file method.

The Article 5 risk map for French companies in the American market: classic triggers, the safe harbors the 1994 treaty still protects, the modern gray zones, and the cost of getting it wrong.