Impot sur revenus - US Subchapter S Corp

Go Back   Expat Forum For People Moving Overseas And Living Abroad > Europe > France Expat Forum for Expats Living in France

France Expat Forum for Expats Living in France Welcome to the France Expat forum. This is the place to meet like minded people who have made France their new home. This forum is ideal for those who have moved to France and those thinking about making France their new home.

Impot sur revenus - US Subchapter S Corp


Reply
 
Subscribe to this Thread Thread Tools
  #1 (permalink)  
Old 17th May 2019, 01:51 PM
Member
 
Join Date: Oct 2016
Location: Béarn
Posts: 183
Rep Power: 0
Leforgeron is on a distinguished road
73 likes received
37 likes given

Users Flag! Originally from usa. Users Flag! Expat in france.
Default Impot sur revenus - US Subchapter S Corp

In looking at the US/French tax treaty as it applies to situations where there is a corporation formed under US law with its only places of business in the US and which has elected Subchapter S treatment, French tax law would appear to govern whether there is a pass-through of income to a US citizen tax resident in France for french tax purposes. Does anyone know the french rules on this? If there is a pass-through, how do you avoid double taxation? Double bad in this case because there was no actual distribution of earnings.

Reply With Quote Quick reply to this message
  #2 (permalink)  
Old 17th May 2019, 04:10 PM
Bevdeforges's Avatar
Super Moderator
 
Join Date: Nov 2007
Location: deepest, darkest Essonne
Posts: 45,410
Rep Power: 23229
Bevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond reputeBevdeforges has a reputation beyond repute
9400 likes received
1223 likes given

Users Flag! Originally from usa. Users Flag! Expat in france.
Default

I'm not sure that France recognizes the US Subchapter S corporations - certainly not in the same way the US tax code does. If you are paid a dividend of some sort, then sure, you have to declare it as a foreign dividend. And when you sell or liquidate your share in the company, then you have a capital gain of some variety.

But a US corporation is a US "person" for tax purposes and I would suspect has no obligation to the Fisc on its income.

OK, that's only a theory on my part, so maybe we have someone here who can jump in with some practical experience in these matters.

Reply With Quote Quick reply to this message
  #3 (permalink)  
Old 17th May 2019, 04:35 PM
Member
 
Join Date: Oct 2016
Location: Béarn
Posts: 183
Rep Power: 0
Leforgeron is on a distinguished road
73 likes received
37 likes given

Users Flag! Originally from usa. Users Flag! Expat in france.
Default

Bev, thanks much for the response. It seems to be a really murky area. LeF

Reply With Quote Quick reply to this message
Reply


Quick Reply
Message:
Options

Register Now

In order to be able to post messages on the Expat Forum For People Moving Overseas And Living Abroad forums, you must first register.
Please enter your desired user name, your email address and other required details in the form below.
User Name:
Password
Please enter a password for your user account. Note that passwords are case-sensitive.
Password:
Confirm Password:
Email Address
Please enter a valid email address for yourself.
Email Address:
Location
Where you live
Expat From Country
Please select the country you originate from. This will appear as a flag when you make posts on the site.
Expat To Country
Please select the country you have either moved to or want to relocate to. This will be presented on the site when you make posts.

Log-in


Thread Tools

Posting Rules
You may post new threads
You may post replies
You may not post attachments
You may not edit your posts

BB code is On
Smilies are On
[IMG] code is On
HTML code is Off
Trackbacks are Off
Pingbacks are Off
Refbacks are Off


Similar Threads
Thread Thread Starter Forum Replies Last Post
CSG déductible calculée sur les revenus du patrimoine - what the hell is this? honeyicedtea France Expat Forum for Expats Living in France 3 30th May 2018 06:02 PM
TWO Déclarations sur les revenus 2016 Voyageur80 France Expat Forum for Expats Living in France 7 10th April 2017 03:18 PM
Avis de non imposition sur les revenus simon50 France Expat Forum for Expats Living in France 7 20th February 2017 11:23 AM

FORUM PARTNERS

ExpatForum.com is owned and operated by VerticalScope Inc.

Retiring Overseas Guides | Moving Overseas Guides | Cost of Living | Health Care Guides


All times are GMT. The time now is 09:18 AM.


Powered by vBulletin®
Copyright ©2000 - 2019, vBulletin Solutions, Inc.
Search Engine Friendly URLs by vBSEO
vBulletin Security provided by vBSecurity v2.2.2 (Pro) - vBulletin Mods & Addons Copyright © 2019 DragonByte Technologies Ltd.