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First, the income may be taxed by both the US and France, which can create double taxation or unexpected tax burden or new levels of tax which can be very significant; second, an increasing number of tax reporting obligations may generate complex and delicate situations (declaration of financial assets or accounts belonging to the non US resident alien spouse, declaration of companies and other structure, declaration of gifts and bequests etc). Failure to comply with tax reporting obligations can result in very significant penalties, extended or sometimes unlimited statute of limitations (period during which a situation can be audited by the tax authorities) or to other sanctions.

Regularization programmes have been proposed by governments in the past containing a reduction of penalties or consisting in tax amnesty enabling taxpayers to come into compliance with their tax situation.

In parallel, the US (via the Fatca legislation), France (as well as many other countries) have introduced new legislation to combat fiscal evasion and concluded bilateral and multilateral treaties notably to increase means of investigation and allow exchange of information (specifically related to bank accounts).

Whether the taxpayer is compliant or not, it has become more important than ever to get to know his/her tax obligations, determine the possible options and plan ahead to optimize tax costs. Cases of non-compliance should be addressed with no delay and regularized based on the best option for the client.

• Conduct an audit of your tax situation to identify risks of non-compliance and opportunities (elimination of double taxation, special dispositions) under domestic law, case law and tax treaties

• Provide you with tax advice and assistance on your tax obligations

• Provide you with tax advice, assistance and representation in the context of a regularization of your tax situation with the US and/or French tax authorities

• Provide you with tax advice, assistance and representation in the context of a renunciation of your citizenship or abandonment of a greencard with the US tax authorities

• Provide you with tax advice /opinion on a specific issue, event or transaction (sale of real estate, tax implications of marriage, inheritance, gift, termination of employment, expatriate or impatriate tax status) or on a particular type of income (stock options, restricted stock, termination payments, settlement payments for injury)

• Assist you with tax formalities (preparation of French and US individual tax returns)

• Provide you with tax advice and assistance relating to the new US Fatca rules

• Provide you with tax advice, assistance and representation in the context of or tax dispute or a tax audit with the French and/or US tax authorities or to claim tax refunds

• Analyze and help resolve a conflict of residence

• Analyze and help resolve double taxation (investment income, restricted shares)