Perspectives

The IRS amnesty for non-willful Americans abroad still works in 2026: who passes the 330-day and non-willfulness gates, what the package contains, and the French mirror to check first.

One trust, two tax administrations, zero coordination: how Franco-American families fall into the 3520 / 1649 AB double reporting trap, and the way out.

Paying dividends to a European parent free of withholding tax: the conditions of the 119 ter regime and the domestic conditions now challenged by case law.

An umbrella brand royalty justifies at best a symbolic remuneration. Indirect profit transfer and abnormal act of management: how to secure your policy.

In France, the proof that a payment received from a trust is not taxable income falls on the beneficiary. Filing duties, wealth tax and the article 990 J levy explained.