Perspectives

Parasol Production rulings, 2026 Finance Act, 10 August 2026 tax guidelines: the Dutreil pact is tightening. Risks and safeguards, including where heirs live abroad.

Internal firm data: two in five contested tax cases are relieved by the administration between filing and hearing. What it reveals, and where we stand.

The FBAR captures the assurance-vie, the PEA, joint accounts and accounts held under mere signature authority: the complete inventory method, the post-Bittner penalty math, and the repair channels.

Presence, vehicle, mobility: the three questions of a US expansion, answered in the only order that avoids double taxation, and the traps of the LLC reflex and the incorporation myth.

Is a management package gain a capital gain or salary? The article 163 bis H regime, the tax deferral trap and international mobility, explained.