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U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

French National Financial Prosecutor's Office Publishes New Guidelines on Judicial Conventions of Public Interest

The new guidelines update those published jointly by the National Financial Prosecutor's Office (Parquet National Financier or "PNF") and the French Anticorruption Agency (Agence Française Anticorruption or "AFA") on June 26,...more

France Expanding Tax Permanent Establishment Definition, Overturning Previous Case Law

The Situation: In December 2020, the French administrative supreme court issued a major decision expanding the permanent establishment ("PE") concept and criteria for both French corporate income tax ("CIT") and value-added...more

Draft French Finance Bill for 2019 Reveals Significant Tax Amendments

The Situation: The first draft of the French government's finance bill for 2019 contains several significant amendments likely to affect key French tax regimes, as well as past and current transactions. The Development:...more

France and Luxembourg Sign New Tax Treaty

The Situation: On March 20, 2018, the governments of France and Luxembourg signed a new double tax treaty that will replace the current tax treaty dated April 1, 1958 (as amended through 2014). The Result: The most...more

French Tax Update - Prior Approval of Cross-Border Reorgs, Abusive Sale and Lease-Back Transaction, Official Guidelines on Foreign...

The present French Tax Update provides an overview of several significant publications issued between the end of 2016 and the first months of 2017...more

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