Norbert
Majerholc
Majerholc
Partner
Taxation
Company buy out by employees
Preferential tax treatment for limiting the financial cost of acquisition debt bt granting of tax reductions for the indebted holding for the takeover.
Company handover
Combination of preferential regimes for preparing donations and/or successions with reduced tax cost: “pacte Dutreil”, tariff reduction, separation of ownership, establishment of a civil society, option for the split and/or deferred payment of rights.
Company reorganisation
Preferential tax regimes for reorganising companies with limited tax costs with, in return, phased reintegration and/or deferred unrealised capital gains while restructuring (capital gains tax deferral and tax reversals).
Declarative assistance
Preparation (data collection), declaration and submission of income tax (especially on property income and capital gains) and wealth tax for resident and non-resident taxpayers.
Estate planning (foreign holding companies)
Establishment of foreign holding companies with minimal substance to prepare a cash transfer following profits in optimised tax conditions; dividend exemption, exemption from capital gains, deductibility of loan interest, no deduction of taxes at from holding company to the financial beneficiary
Financial VAT
Board of investment services providers (PSI) on their VAT outlines as far as Undertaking for Collective Investment in Transferable Securities (UCITS) and management under mandate are concerned.
International Mobility and Optimisation of Tax Deductions
Combined implementation of tax and social security rules in order to reduce the overall tax ratio applicable to income from activities and property income for people who carry out most of or all of their business activates abroad.
International recovery assistance
Implementation of preparatory cross border property reorganisations to benefit limitations resulting from private international law relating to international recovery assistance.
Litigation on the lawfulness of additional levy
Pre-litigation and litigation on the legality of parafiscal taxes in regards to the principles of French community law in order to challenge their legality, especially in the absence of notification to the commission in the event of a substantial modification of their regime and their quality of
Local taxation
Review of cost optimisation of territorial economic tax costs and risk assessment.
Management package
Employee share ownership and sui generis which develop indirect/additional compensation benefiting from a preferential tax and/or employment treatment in relation to a direct compensation as salary.
Optimisation of tax deficit management
Techniques to offset the tax losses: restructuring regimes covered by French common law, transfer of assets, write-off of loans, subsidies, independent revaluation, etc.
Organisation of real-estate investments
Choosing the most appropriate tax vehicle: French listed property investment companies (SIIC), collective undertaking for real estate investment (OPCI), foreign structure, arbitration between transparent and opaque tax regimes etc.
Support and cross-border succession regulation
Assessment and quantification of risks related to the regularisation of undeclared foreign assets by the heirs of the deceased. Comparison between adjustments associated with an unforeseen post-inheritance inspection and spontaneous regularisation by the heirs.
Tax income (tax exemption)
Property audit leading to the recommendation of the most appropriate tax revenues given the structure of revenues to mitigate income tax: LMP (non-professional furnished letting), Loi Girardin, French overseas departments and territories (DOM TOM), Share Savings Plan (PEA), high-risk mutual fund
Trusts and funds
Implementation of vehicles for transmission and management of assets in light of fiscal constraints of French domestic law for entities located in countries with privileged taxation. Management of reporting obligations.