A US living trust can create unexpected French tax and reporting consequences once someone moves to France, and French tax residence is not determined the way most people assume.
Thomas Dubanchet, a French tax lawyer and founder of Bespoke, joins the show to explain how France treats US trust structures, why French tax residence cannot be determined by a day count alone, and how a formal written position from French tax authorities can address specific situations before committing to a move.
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CHAPTER TIMESTAMPS
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00:00 - Why a French tax lawyer builds his practice around US-connected clients
05:25 - The planning gap FATCA created between US and French systems
08:23 - The common mistake of optimizing your old state's plan instead of coordinating with the new one
19:03 - How France treats US living trusts
23:15 - Requesting a formal written position from French tax authorities
25:36 - Why French tax residence is not just a day count
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ABOUT THE GUEST
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Thomas Dubanchet is a French tax lawyer admitted to the Nice Bar and founder of Bespoke, a French tax law firm advising US-connected individuals and families on relocation, French tax residence, trusts, and estate planning. He works with clients' US tax and legal advisers to coordinate planning across both countries. He is a member of the Passport To Wealth® Directory.
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ABOUT YOUR HOST
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Arielle Tucker, CFP® & IRS Enrolled Agent with Connected Financial Planning, is a cross-border financial planner based in Switzerland helping Americans living abroad navigate U.S. taxes, international investments, and cross-border financial planning.
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ABOUT PASSPORT TO WEALTH®
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Passport To Wealth® is the platform for current and aspiring US expats. We connect globally mobile Americans with vetted, licensed cross-border financial advisors, tax professionals, and relocation experts who understand the financial and legal complexities of life abroad.
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LINKS & RESOURCES
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Website: https://www.passporttowealth.com
Instagram: https://www.instagram.com/passporttowealthofficial
LinkedIn: https://www.linkedin.com/company/passport-to-wealth
Find Thomas Dubanchet in the Passport To Wealth® Directory: https://www.passporttowealth.com/thomas-dubanchet
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This episode is for educational purposes only and does not constitute tax, legal, or financial advice. Individual circumstances vary. Consult a qualified cross-border financial professional before making any financial or tax decisions.
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