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Globally More Mobile: From Rental Reform to Tax Transition to a One-Night Stand at Le Louvre

French Property Insider

Volume XVII, Issue 15
Thursday, April 11, 2019 • Paris, France

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APARTMENT FOR SALE: 26 rue des Francs Bourgeois, Paris 3rd Arrondissement
Adrian Leeds Group - Apartment for Sale
Two-Bedroom, Two-Bathroom Fully Furnished Triplex, 88m2 (950 sq. ft.)
The 88 square-meter apartment is in a portion of the building that was once the carriage-house of a 17th-century “Hôtel Particulier” and was designed and decorated by our illustrious interior architect, Martine di Mattéo.
The apartment is situated on three levels:
1) a ground level living room/dining room with fully-equipped kitchen with laundry/utility area,
2) a master suite on the upper level including an arched window that spans the entire length of one wall with a separate toilet, full bathroom with claw-foot tub, shower and sink and
3) a second bedroom and bath on the lower level, all which provide its occupants with a real sense of privacy.
The main entry is on the beautiful courtyard and two large mirrored windows face the street providing complete privacy.
The apartment is being sold with all the furnishings valued at 35,000€.
Reference: #115

NOW €1,170,000!
For more information email Carsten Sprotte: [email protected] 

Bonjour French Property Insider Subscriber,


ELAN - France

The ELAN laws, adopted by the Senate on October16, 2018, were designed to "reform housing, planning and digital technology." What the main focus of these laws is, is to find a solution to the housing shortage, particularly in Paris, and reform some of the rental laws that make finding a home even more difficult for those needing accommodations for more than one month and less than one year, thanks to our new and very mobile/global society.

I urge you to read from the official government website (in English), citing those issues that pertain most closely to our own hearts. The following text is an extract:    

     For several decades, our daily lives have been changing. We change jobs more often. Our relationship with work is shifting. We are or would like to be more mobile than we were in the past. Family models are more diverse (reconstituted and single-parent families, for example). Digital technology is omnipresent. We want to be more self-reliant and more responsible towards our loved ones and the planet.

     France is changing, but a home remains a basic need. It is the place of privacy, rest, family and study. It can also constitute an asset or an investment.    

     Housing is often too expensive. Regulations, the cost of land, administrative procedures and legal actions: all of this can result in higher bills for French people. In certain areas, the supply of housing is lower than demand, which contributes to rising prices. Many mid-sized cities, on the other hand, suffer from abundant but ill-adapted housing and business closures. Too many people are still the victims of poor housing.

     Developed from the ground up, the ELAN bill provides a global response to these concrete issues.

     It has two objectives:

    Open up and offer new opportunities: facilitate the building process while ensuring all stakeholders are responsible for the objective to be achieved, in order to construct and renovate more buildings.
    Protect and give more to those who have less: strengthen the social housing model, promote mobility in social housing and make allocations more transparent, combat substandard housing, but also create new forms of solidarity and reduce the territorial divide.

    16 October 2018: the ELAN bill is definitively adopted by the Senate.

    12 June 2018: the bill is adopted on first reading at the National Assembly.

    30 May 2018: examination during a public session at the National Assembly.

    4 April 2018: introduction of the ELAN bill during the Council of Ministers by the Minister of Territorial Cohesion, Jacques Mézard, and Minister of State, Julien Denormandie.

    20 September 2017: presentation of the Housing Strategy.

    July 2017: consultation with housing, construction and planning stakeholders to identify needs and proposals. The consultation produced over 1,200 proposals. It ended on 10 September 2017.

In addition, the Chambre de Notaires de Paris offers up a flyer (in French) explaining the new laws and information on their website. (Download the PDF)

By Monte Silver, Silver & Co., Attorneys at Law:

    My personal note: The following information from Monte Silver about the Transition Tax affects simple French (and other non-U.S.) residents like me, who have companies in their resident countries, to pay a tax on corporate earnings, simply because we hold U.S. passports. This is not the same as a big U.S. company going "offshore" for tax purposes! And the big joke on us, too, is that who in their right mind opens a business in France TO SAVE ON TAXES!? Monte Silver is our advocate to fight this tax transgression on the part of the U.S. government.

Trump Signing Transition Tax - Photo Credit: American Expat Financial News Journal Signing Transition Tax - Photo Credit: American Expat Financial News Journal

This law signed by President Donald Trump in December 2017 created new taxes for corporations that have shifted their profits offshore for years. The Repatriation Tax (or Transition Tax) forced large U.S. companies like Apple and Google to pay a sizable tax on profits they held outside the U.S. in their foreign subsidiaries (called CFC - controlled foreign corporations). Specifically, all profits of these CFCs that accumulated between 1986 through December 31, 2017 were treated as income to their U.S. parent company (Apple and Google, for example) and taxed at 15.5% for profits held in cash form, and 8% for profits held in non-cash form.

Although not the target of the tax, U.S. citizens or Green Card holders living abroad U.S. who owned interests in companies incorporated outside the USA ("Expats") suddenly found themselves subject to the tax. Why? Under the law, individuals were treated the exact same way as large U.S. corporations. Therefore, if an Expat owned at least 10% of a foreign corporation, and over 50% of that foreign corporation was owned by Americans, that corporation was a CFC for purposes of the tax. Accordingly, Expats were required to pay the same tax as Apple on accumulated profits, with one catch, their rates were higher — 17.54% (for cash) and 9.05% (for non-cash).

Here's an update on the Transition Tax installment payment,

As you are aware, last April (2018), we received the first relief from Treasury. The relief was quite clear and stated that if the person’s ordinary filing date was June 15, then the time to make the installment payment was June 15. See the text of the relief

The second relief we received from Treasury, in June 2018, stated that if an individual shareholder of a CFC had less than $1,000,000 in total Transition tax liability, then the first payment (due April 15 for US based taxpayers, or June 15, 2018 for Americans living abroad) could be postponed till April or June 15, 2019 respectively. In other words, by April 15 or June 15, 2019, the first and second Transition tax installment payment is due.

Will any relief be obtained by the payment deadlines? By April 15, 2019 — no. By June 15, 2019 — which is most relevant to Americans abroad, the answer is — quite possibly.

How is this possible? Simple — the lawsuit. Clearly, the government has endless resources to fight lawsuits and would fight this lawsuit as well. However, the relevant senior officials realize that our lawsuit is iron clad. Accordingly, the lawsuit has hit a nerve, as I predicted it would. The lawsuit has the potential to bring to light many things that the senior officials do not want exposed. Even worse, this same lawsuit can be used for many many other matters. Very bad news.

I am not at liberty to discuss what is going on behind the scenes. All I will say is that Transition Tax relief by June 15, 2019 is feasible and is my target. You may want to consider this in deciding when to make a Transition tax installment.

Monte Silver
Monte Silver, Adv. (Israel & CA)
Silver & Co. Attorneys at Law
Hahoshlim 6, Building C, 7th Floor, P.O.Box 12069
Herzelia Pituach 46733 Israel
Tel: +972-9-9603799
Fax: +972-9-9603798
Mob: +972-544-232-683
Email: [email protected]


Photo Credit: For Airbnb, Photo © by Julian AbramsPhoto: For Airbnb, Photo © by Julian Abrams

Photo Credit: For Airbnb, Photo © by Julian AbramsPhoto: For Airbnb, Photo © by Julian Abrams

Has Airbnb gone nuts? This coming April 30th, some "lucky" person is going to spend the night side by side with Mona Lisa in the Musée du Louvre. Really? Airbnb has launched an international contest that will award one winner and their guest to sleep beneath the Louvre's pyramid. They call it "A Night with Mona Lisa. The World-famous Musée du Louvre joins forces with Airbnb to give unrivaled access to the museum and its masterpieces.

"It's just one night, but it includes a private tour of the museum and its famous works of art, which you will have all to yourselves — Mona Lisa, Venus de Milo and even a private concert in Napoleon III's Apartments. All this is part of the Louvre's 30th anniversary celebration.

Read more about the exciting evening on the Airbnb site and register now! You only have untill Midnight April 12th (French time – GMT+1)! Go to NOW!


A bientôt,

Adrian Leeds - Paris, France

Adrian Leeds
Adrian Leeds Group

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Adrian Leeds Group - Paris, France

Living in France for several years, Adrian Leeds has accumulated valuable experience and information as well as developed valuable contacts. She is able to assist you as much as possible and when necessary, put you in contact with one or more of our professional associates to provide the help you need.


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