Counsellor
Reporting obligations of individuals
Annual income tax return
Declaration of capital gains on the sale of securities (2074): determination, securities benefiting from a tax deferral or relief scheme, transfer strategy (tax cost simulation and choice of applicable regime)
Different High Income Contribution (HRDC): calculation of deposit and reporting arrangements
Property tax : valuation of assets, determination of deductible liabilities, haircuts, exemption from professional property, capping
Civil real estate companies : choice and consequences of the tax system (IR / IS), distribution and exit of cash
Digital assets: determination and reporting of capital gains (2086), accounts opened on foreign platforms (3916-bis)
Tax optimisation of exceptional or deferred income: quotient system, spread, tax mitigation options
Corrigendum and spontaneous regularization before check
Business tax management
Group scheme : establishment and monitoring of tax integration, scope, reprocessing, entry and exit of companies, tax integration agreements
Internal growth : filialisation, partial active contribution, creation of holding companies, intra-group financing
External growth : tax audit of acquisition (due diligence) or sale (soldor due diligence), structure of the repurchase and its financing, LBO / OBO, deductibility of financial charges
Restructuring : mergers, divisions, contributions, universal transfer of assets, concession scheme (article 210 A of the CGI) and applications for authorisation (transfer of deficits)
Business transfer (Article 151 septies, 151 septies A, 151 septies B and 238 quindecies of the CGI), allowance in case of retirement of the manager (Article 150-0 D ter of the CGI) and arbitration between transfer of securities versus transfer of funds.
Taxation of the leader : compensation / dividends arbitration, social and tax regime of agents, benefits in kind, current accounts of associates
Employee share ownership Free share allocation (AGA), BSPC, stock options, BSA, Restricted Stock Units, U.S. or British stock options, tax and social treatment, distribution of acquisition gain among States, reporting obligations of the beneficiary
Management packages : structure and security under the regime under the 2025 Finance Act (article 163 bis H of the CGI)
Upstream security : tax returns, formal positions of the administration, prior agreements
Business real estate : direct holding arbitration / SCI, sale of the operating property, registration rights
Heritage tax strategy
Property tax : optimisation of the holding structure, dismemberment, debt and deductible debts, arbitration between early repayment and retention of a loan
Real estate acquisition strategy : choice of vehicle (direct detention, indivision, SCI to the IR or to the IS, family SARL), dismemberment of property, method of financing, income regime (bottom-up, furnished, LMNP / LMP), anticipation of surplus value of disposal
Doutreil Pact (article 787 B of the CGI): eligibility of the activity, host holding, collective and individual commitments, articulation with the donation in full ownership or in bare ownership, follow-up of declaratory obligations and security of tenure
Heritage holding : constitution, contribution-cession and deferment of taxation (article 150-0 B ter of the CGI), obligation to reinvest economically and follow up on the deadline and declaratory, donation of the securities brought, purging of the deferral, exit of the deferral in case of departure from France
Early transmission : donation in full ownership or bare ownership, donation-sharing, donation before assignment
Defend you
Tax control and tax pre-content
Tax control assistance : requests for information and information, auditing of accounts, adversarial examination of the personal tax situation (ESFP)
Accounts, contracts and assets held abroad : spontaneous adjustment
Pre-contentious : reply to a proposal for rectification, hierarchical appeals, referral to the competent committees.
Disputes : representation before the competent courts according to the tax at stake.
Negotiation : transaction with the tax administration, negotiation of remission of penalties and interest on late payment
Collection: : challenge of proceedings, forced opposition, payment plans, stay of payment and provision of guarantees
Commission des Chefs de Services Financiers (CCSF) : preparation of the file, negotiation of debt relief and repayment plans
Tax solidarity discharge between spouses or partners (art. CGI 1691 bis): preparation of the application for a tax solidarity discharge
Tax litigation
Defence before the competent tax courts depending on the nature of the tax concerned
Professional professions
Structure of the liberal exercise
Opportunity and timing of transition: liberal exercise company (SELARL, SELAS), multi-professional exercise company (SPE)
HAVErbiting between IRS (BNC) and IS taxation : simulation, impact on remuneration, social security contributions and cash flow
Transition from BNC to IS: contribution of clients or the Liberal fund, tax deferral (article 151g of the CGI)
Transformation of the exercise structure (in particular SELARL to SELAS): fiscal and social consequences, management regime, exit from reserves
Piloting compensation for SEL partners
Contribution or transfer of a liberal fund, patient, client or presentation fee: qualification, valuation, occupational surplus-value scheme
Exemption schemes Art. Article 151 septies, art. 151 septies A (retirement)
Heritage strategy and transmission
SPFPL (Professional Financial Participation Corporation): financing of acquisition of securities, mother-daughter scheme, tax integration, capital holding constraints
Detention of professional premises: SCI, dismemberment, arbitration between rent and property, IFI and exemption for professional property
Knowledge of ordinal and ethical rules
Consideration of ordinal and ethical rules specific to each profession in the drafting of acts and the choice of proposed montages