Sopher International Tax

An affiliate of Sopher + Co, offering US and French tax advice

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US TAX

We are able to provide a fully integrated US tax service offering advice to UK and European individuals and companies on all stages of investment in the US, including:

  • Entity selection (partnership, corporation, proprietorship).
  • Financing the investment using debt, equity, structured debt instruments, etc.
  • Treaty planning.
  • Operational considerations – maximising deductions for capital recovery (depreciation, amortisation), intellectual property planning and planning using head offices charges.
  • Efficient repatriation of earnings (eg, through tiered investments).
  • Structuring the unwinding of investments.

We are also able to provide a fully integrated US tax service to assist US citizens, green card holders and US companies with their UK and European investments and operations, including:

  • Advising on structuring investments, giving due regard to US-controlled foreign corporation and passive foreign investment company regimes;
  • Foreign tax credit planning.
  • Capital gains tax planning.
  • Advising on estate and gift taxes.
  • Advising on expatriation and exit tax.

For all of the above we offer consultion services as well as assistance with the preparation of all tax and information returns and other associated tax filings, in addition to Foreign Bank Account Report (FBAR) and Foreign Asset Report forms.

For further information please contact Ed Rieu.

FRENCH TAX

The French tax department offers expertise on a number of French tax-related matters, relating to both corporations and private clients, which include advising:

  • Investment funds on the tax aspects of private equity transactions (up to €500m transaction).
  • Banks and financial institutions on the tax regime of financial products (bonds, stocks, life insurance products, warrants, etc).
  • Multinational companies on transfer pricing issues and group restructuring tax issues.
  • Managing directors and shareholders on the tax optimisation of capital gains, income tax and wealth tax.
  • Wealthy individuals on their relocation issues (Belgium, Luxemburg, Switzerland, Morocco and Israel).
  • Wealthy families and foreign investors on the tax optimization of French real estate investments (international structuring), trust legislation, bank secrecy and estate tax issues.
  • Private shareholders on the tax implications of their group restructuring (contribution of assets, mergers, international brand’s reorganisation).