fields of activity

With a broad range of knowledge and over thirty years of experience in U.S., French and international tax matters, our firm provides the following services to a clientele situated across the globe:

  1. International tax planning for income, estate, gift, trust and wealth tax matters.
  2. Preparation of U.S. and French income, estate, and gift tax returns and declarations.
  3. Fiscal analysis and optimization with respect to cross-border investments, retirement abroad, and international trust, gift, and estate planning
  4. Preparation of French wealth tax (ISF) declarations for both current and back filings
  5. Minimizing tax and social security costs through judicious use of international tax treaties and social security totalization agreements
  6. Design and application of executive compensation plans and tax equalization plans for executives abroad, including tax planning for stock options and deferred compensation
  7. Assistance with U.S. and French tax examinations and queries, including voluntary disclosures
  8. Analysis of the tax consequences of renouncing U.S. citizenship or long-term resident status

International tax planning for income, estate, gift, trust and wealth tax matters

In today’s global economy, more and more individuals find themselves subject to a wide range of international tax rules as they move abroad for employment or personal reasons. Likewise, individuals with investments, real property and other assets in different countries are required to report their holdings in both their home countries and in those where their investments and property and located.
We offer a wide arrange of services and planning tools to assist individuals as they confront different international tax issues, helping them minimize their tax exposure while adequately meeting both home and foreign country reporting requirements.

Preparation of U.S. and French income, estate, and gift tax returns and declarations

U.S. citizens and long-term residents (“green card” holders) residing abroad face the added burden of reporting their income, gifts and estates in both their country of residence and in the U.S. At the same time, French residents with income in the U.S., and U.S. residents with income in France, are required to report income, gifts, and estates to both countries. In order to avoid the risk of double taxation, and to help taxpayers meet their international filing requirements, we prepare all types of U.S. and French tax returns and declarations, including, but not limited to:

• U.S. Form 1040 and all related schedules, 1040NR, 1120, 1120-S, 1065, 5471, 8865, 8621, W – 7, W – 8BEN, W–9, Foreign Bank Account Form TD F 90.22 – 1, Estate Tax Form 706, Gift Tax Form 709, etc.
• French Forms 2042, 2042– C, 2044, 2031, 2035, 2065 (SCI – IS), 2074 (SCI – IR), 2725 (ISF), 2746 (3%), 3916, etc.

Fiscal analysis and optimization with respect to cross – border investments

When making decisions regarding international investments, it’s essential to consider the tax consequences of placing money in overseas markets or investing in property located abroad. For those looking to retire in a foreign country or to return to their home country after a career spent overseas, planning for their financial futures includes an extensive analysis of their tax exposure, and how it will affect income streams and annual expenditures. Finally, successful planning for international trusts, gifts and estates requires an understanding of both the civil and fiscal laws of each country involved, allowing heirs and beneficiaries to receive a smooth and tax-effective transmission of assets. Such endeavours necessitate a broad knowledge of current international tax laws, which our experienced team can provide along with a range of planning tools and strategies, carried out in conjunction with attorneys and agents situated around the world.

Preparation of French wealth tax (ISF) declarations for both current and back filings

France remains one of the last Western nations to impose a wealth tax (ISF) on the net assets of French residents, as well as on non-residents with property located in France. And although the French government has reduced the burden somewhat over the past years, the tax remains an annual, laborious obligation, and can prove costly for individuals of a certain net worth. We assist our clients in preparing their annual ISF return, helping them take advantage of recent, favourable changes to French tax laws and international treaties, as well as evaluating real property and other types of assets. We also help those taxpayers who find themselves in a situation where they need to back file several years of wealth tax returns, negotiating with the tax authorities to reduce the tax liability, penalties and interest charges.

Minimizing tax and social security costs through judicious use of international tax treaties and social security “totalization” agreements.

Any decision to accept employment overseas includes weighing the income taxes and social security costs of the future country of residence. For U.S. citizens working in foreign countries, the decision is complicated by an American fiscal system that taxes citizens even if they live and work abroad. To avoid the risk of double taxation, and to minimize the tax costs of overseas employment, we help both companies and individuals take advantage of current international tax treaties, as well as internal tax laws and provisions. For social security costs, we assist our clients in utilizing international “totalization*” agreements that allow them to continue contributing in their home country while working overseas, guaranteeing a more cost effective coverage for health insurance plans, and ensuring that pension obligations are not broken.

* “Totalization” agreements are bilateral treaties which eliminate dual coverage, as well as dual employer and employee taxation for social security, while providing continuity of coverage for an individual who is employed abroad.

Design and application of executive compensation plans and tax equalization plans for executives abroad, including tax planning for stock options and deferred compensation planning for stock options and deferred compensation.

For executives working abroad or planning to do so in the future, we work directly with them or their company’s HR departments to analyze the tax and social security costs of overseas employment. We provide detailed calculations for tax equalization plans, including “gross-up” calculations and “net-in-pocket” calculations to help executives and employers evaluate the tax consequences of working in one or more countries. Finally, we analyze the often complicated tax effects of stock compensation and deferred compensation plans, helping to minimize the tax exposure of stock options exercises and payouts.

Assistance with U.S. and French tax examinations and audits, including voluntary disclosures.

For individuals facing tax examinations and audits in the U.S. or France, we provide full guidance and assistance in dealing with the IRS or the French fisc, representing taxpayers and negotiating their liabilities, penalties and interest charges. Recent times have also shown an increase in taxpayers making voluntary disclosures of previously unreported income and bank accounts, and we can accompany such taxpayers by preparing back filings and calculations, as well as analyzing the tax advantages available under amnesty provisions, internal laws and international treaties.

Analysis of the tax consequences of renouncing U.S. citizenship or long-term resident status.

The decision to renounce one’s U.S. citizenship or long-term resident (“green card”) status is often motivated by tax purposes. While this may not be the only reason for giving up U.S. status, the Department of Treasury’s complex and far-reaching tax system directly affects the employment, financial and estate planning possibilities of U.S. citizens and former long-term residents living abroad, forcing them to contemplate such a choice. Recently, Treasury has enacted an “exit tax” meant to deter those wishing to renounce their U.S. status, while other expatriates find themselves obliged to make U.S. filings for a 10-year period following expatriation. We have a wealth of experience dealing with U.S. expatriation issues, and can assist taxpayers in understanding the consequences of losing U.S. status, walking them through the renunciation process and handling all related filings.