Litigation

Article 751 of the CGI and Usufruct : Tax presumption and implications Article 751 of the French General Tax Code (CGI) establishes a major tax presumption with regard to inheritance and gift tax. This provision specifically concerns dismembered assets, notably...

Article 751 du CGI and Inheritance: Presumption of Ownership Article 751 of the French General Tax Code (CGI) establishes a presumption of ownership that can have significant consequences in the event of inheritance. This tax provision allows the administration to...

Tax Assumptions: Understanding and Challenging the Administration's Mechanisms Tax presumptions are a powerful legal tool enabling tax authorities to establish the existence of certain facts without having to provide direct proof. These mechanisms reverse the burden...

150-0 B ter tax deferral: Mechanism and conditions of application Tax deferral is a strategic tax mechanism that allows the deferral of capital gains taxation in certain asset transactions. Article 150-0 B ter of the French General Tax Code provides taxpayers with a...