French Life Insurance “101” – For U.S. Persons, Run Away
France is a popular destination for American expatriates. However, once in France, they may face complex tax challenges notably with a popular European saving vehicle, the French life insurance structure. This financial vehicle is an effective opportunity for investment and estate planning from a French tax perspective, but it may not be viewed favorably under U.S. tax law. Sophie Borenstein (Klein Wenner – France) and Neha Rastogi (Ruchelman P.L.L.C. – U.S.) will explain the French life insurance structure along with the tax implications and reporting obligations in each jurisdiction when held by a U.S. individual (i.e., a U.S. citizen or green card holder).
The program will cover the following:
-What is a French life insurance?
-Is it similar to the concept of US life insurance?
-How a French life insurance works?
-Overview of the French legal and tax regime
-U.S. taxation and U.S. reporting of French life insurance
OUR SPEAKERS
Sophie Borenstein is a partner and leads the tax team of Klein Wenner. Sophie specializes in French and international taxation and advises a number of private clients, high-net-worth individuals and families, executors, and trustees on international estate planning and succession, trust issues, tax compliance, private real estate taxation, and on tax structuring for acquisition and disposal of yachts. She also provides tax advice for sportspeople and artists. She advises clients both in terms of advice and litigation.
Sophie has also developed a particular expertise in wealth management and tax management in France as well as in cross-border issues, particularly with Anglo-Saxon countries (United States, United Kingdom, Australia, Jersey, and Guernsey, etc.) and German country (Germany, Austria), but also Switzerland, Belgium, Luxembourg, Italy, Canada, Saudi Arabia, the United Arab Emirates, Lebanon, Singapore, Spain, and Portugal.
In addition, Sophie is the head of the tax and private clients practice group of Pangea Net and she is a member of the International Fiscal Association (IFA), of the Institute of French tax lawyers and counsels (IACF), and of the European EPSG (Estate Planning Skill Group.
Neha Rastogi is a Senior Associate at Ruchelman P.L.L.C. where she regularly advises domestic and foreign clients on tax issues emanating from cross-border presence and investments. Her practice includes planning for global families and businesses with cross-border investments, multi-generational family wealth planning, and U.S. real estate investment structures. She writes regularly for Insights, the international tax journal published by Ruchelman P.L.L.C.
Before joining the firm, Neha qualified as an advocate and as a member of the Institute of Chartered Accountants of India and worked at a leading tax law firm based in New Delhi.
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