• French Tax Administration’s Approach to US Partnerships Operating in France

    March 23 2012, 01:00 - 01:00
    Location: AmCham France - 77 rue de Miromesnil, 75008 Paris

    Recent Developments in the French Tax Administration’s Approach to US Partnerships Operating in France

    The chairman of the Taxation Task Force of the American Chamber of Commerce in France is pleased to invite you to a breakfast roundtable to discuss recent developments in the French Administration’s taxation of partners of US law firms operating in France, as well as other tax and accounting trends with a direct and important impact on such partnerships.

    International law firms doing business in the form of US partnerships in France have had to face the consequences of a very strict reading by the French Tax Administration of the US-France Income Tax Treaty. Partners of such firms have been threatened with double taxation on their allocated shares of revenue from outside the US or France, contrary to French tax jurisprudence and traditional tax principles. This has resulted in a plainly discriminatory situation with respect to US law firms practicing as partnerships in France that requires swift action.

    One US law firm in France succeeded in obtaining a positive ruling on this issue. A representative of that firm will present for discussion the situation they faced and how they resolved it. Other presenters will also discuss possible solutions. We hope that as a result of these discussions, effective and lasting solutions may be found.

    Other challenges faced by US law firms operating in France will also be discussed.

    Proposed agenda :

    Overview of situation of US law firms practicing as partnerships in France

    Recent income tax challenges facing resident and non-resident partners

    Finding solutions to specific accounting needs of US law firm-partnerships

    Determining the taxpayer for local tax purposes and other related issues

    Considerations regarding VAT

    Employee’s profit-sharing plans in a partnership setting