Investment Structures: We advise on the French – US tax implications of US and non-US investment and insurance structures.  We advise on tax issues for Americans investing abroad, such as the Passive Foreign Investment Company (“PFIC”) and controlled foreign corporation (“CFC”) regime. 

Trust and Estate Planning and Administration:

• We advise on the planning and administration of estates subject to French and US rules, including Americans residing in France or with French assets. 

• We advise on the impact of trust structures under the French regime applicable to trusts.  

• We advise on the use of remainder interest strategies (démembrement) in France.  

Pre-Immigration Planning: We advise on the impact of a change in tax residence between France and the United States, including for entrepreneurs and executives with significant interests in French and US businesses.  

Real Estate:  We advise on investments in real estate in France and the United States, including

• the process of identifying, negotiating and closing the transaction under local law,

• options for structuring the ownership and

• French – US income and estate and French wealth tax implications of the ownership.

Holding companies:  We advise on the use of personal holding company structures, such as real estate holding companies and family holding companies, including

• the US tax treatment of such entities and

• the considerations relevant to the choice of entity in such structures.

International compensation packages:  We advise on the impact of common incentive compensation structures in France for Americans.