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ARTICLE · 05 SEPTEMBER 2022

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French Tax Obligations Relating To Trusts

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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Since French trust legislation was adopted in 2011, some early uncertainties about its application have been resolved. The connections with France that trigger application of the legislation...

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Since French trust legislation was adopted in 2011, some early uncertainties about its application have been resolved. The connections with France that trigger application of the legislation have been clarified and expanded and reporting procedures have been standardized, with the reported information being fed into an official register accessible to authorities and others. Tax obligations resulting from the legislation have been simplified since the French general wealth tax (impôt de solidarité sur la fortune, or ISF) was replaced beginning in 2018 by the real estate wealth tax (impôt sur la fortune immobiliere, or IFI). An update of official commentary published March 30, 2022, modified some rules relating to reporting by trustees, and recent court cases provide clarification on some points, but questions remain.

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