Our focus at BPS Tax Services is in the following areas:
- Preparation of U.S. and French tax filings.
- On the U.S. side, preparation of federal tax returns including disclosures for non-U.S. assets and entities (Forms 8938 (the so-called FATCA form), 5471 for foreign corporations, 8865 for foreign partnerships, 8858 for foreign disregarded entities, etc.), state tax returns, FBARs (FinCEN 114), returns for certain closely-held entities, such as partnerships, LLCs, and s-corps, estate tax returns, gift tax returns, and trust returns, and informational filings concerning the receipt of non-U.S. gifts, inheritances, and trust distributions.
- On the French side, preparation of income tax returns and disclosures of non-French accounts, wealth tax returns (ISF/IFI), and disclosures for U.S. trusts.
- Advise on U.S. and French compliance, including regularizing prior mistakes under Internal Revenue Service compliance programs, such as the Offshore Voluntary Disclosure Program (OVDP) and streamlined filing compliance procedures. Preparation of filings under these programs and representation of clients before the IRS, if needed.
- Tax Planning and Optimization, particularly where there are dual U.S. and French concerns.
- Income and wealth taxation and planning.
- International compensation, including as it relates to stock options and other stock incentives and common compensation incentives broadly offered in the U.S. and France, such as 401ks, deferred compensation, PERCOs, PEEs, participation, etc..
- Investment structures, including the U.S. treatment of French products, such as assurance vie and other financial assets, and French structures such as holding companies, SCIs, and SCs, PFIC taxation and avoidance, and CFC taxation and avoidance.
- Estates, gifts, and trusts, specifically how U.S. trusts play out in France, the U.S. treatment of usufruit/nue-proprieté, and assisting with the repatriation of American assets to France.
- Retirement planning and certain social security totalization agreement issues.
- Expatriation, renunciation of U.S. citizenship and relinquishment of green card.
- Assist clients in understanding their present situation and the tax consequences if they were to expatriate, including exit tax and methods of avoiding exit tax and covered expatriate status and non-resident taxation on future U.S. income.
- Preparation of Form 8854 and tax returns, including non-resident returns (1040NR) and dual-status returns.
- Representation of clients before the Internal Revenue Service and French tax authorities in examinations or other tax office inquiries.