France–United States Real Estate Taxation: Structure Holding and Maintain Net Return

A real estate investment between France and the United States is never about the tax treatment of the property in its country of situation.

Owner's residence, holding structure, rental income, financing, transfer taxation and conventional mechanisms must be articulated to assess the actual tax cost of the transaction.

Mode of holding can transform taxation of investment

Direct retention, French company, American structure or more elaborate organization: each scheme produces different effects on income, flow flow, deductibility of certain charges and future taxation of resale.

An effective structure during the detention phase may become less relevant at the time of transfer. The analysis should therefore cover the entire investment cycle, with particular attention to the retained net value.

Avoiding an advantage in one country being neutralised in the other

The Franco-American tax convention makes it possible to organise the distribution of the right to impose and avoid certain double taxation, but it does not exempt a reflection on the structure itself.

The strategy is to compare the effects produced in France and the United States in order to identify the most efficient installations, to limit tax friction and to improve the overall profitability of the real estate assets.

Master Edouard Pruvost specializes in consulting on international tax and real estate strategy. To have your investments structured between France and the United States analysed and to benefit from tax strategy advice, contact the firm.