France can tax your US LLC as a corporation at 25%. What triggers requalification, the 10 year audit window, and how to register before it happens.
Vincent Berthier De Bortoli
Founder & International Tax Lawyer, VBDB Tax Attorney, Chambéry, France
Avocat, Specialist in tax and customs law, TEP
Founder of VBDB Tax Attorney in Chambéry. A French avocat, certified specialist in tax and customs law and full member of STEP, he advises individuals and families on cross-border personal taxation, trusts and international estate planning, in French and English.
Credentials
- Avocat (French lawyer), member of the Chambéry Bar, sworn in before the Chambéry Court of Appeal in December 2016
- Certificate of specialisation in tax and customs law (droit fiscal et droit douanier), awarded by the Conseil National des Barreaux
- Full member of STEP, the Society of Trust and Estate Practitioners (TEP)
- Master II in Corporate Law and Taxation (GEFIRE) and university diploma in advanced taxation, University of Auvergne, Clermont-Ferrand
- Master's degree, Osgoode Hall Law School, Toronto
- Law degree, Université de Savoie, Chambéry
Vincent Berthier De Bortoli is an avocat registered with the Chambéry Bar (Ordre des avocats du barreau de Chambéry) and is listed in the Bar's public directory, with a tax law specialisation, at his practice address in Chambéry. He was sworn in before the Chambéry Court of Appeal in December 2016. He holds the certificate of specialisation in tax and customs law (droit fiscal et droit douanier), awarded by the Conseil National des Barreaux. He is also a full member of STEP, the Society of Trust and Estate Practitioners (TEP). VBDB Tax Attorney is the trade name of his individual practice: SIREN 834 379 166, 89 rue Amiral Gérard Daille, 73000 Chambéry.
Areas of expertise
- International and cross-border personal taxation
- Tax residency and tax treaties
- Trusts and comparable entities
- International estate planning and inheritance tax
- Interaction of French, Swiss and US tax rules
- Tax and trust returns, compliance and tax disputes
- Taxation of artists and athletes
- Corporate tax
What Vincent Berthier De Bortoli reviews
Reviews French and international tax content for factual accuracy, with a focus on tax residency, trusts, and cross-border estates and inheritance. Does not review US federal tax filing, immigration, investment selection or healthcare content.
- French tax residency rules and the tie-breaker tests of the US-France tax treaty
- Tax planning before and after a move to France
- Trusts, including US revocable and living trusts, with a French-resident settlor or beneficiary, and French trust reporting
- French inheritance and gift tax on cross-border estates, and the US-France estate and gift tax treaty
- International estate planning for families with assets in several countries
- The IFI French wealth tax for international households
- French tax audits, reassessments and tax disputes
Does not review
- US federal tax returns and IRS filing (1040, FBAR, FATCA)
- Visa, residency and immigration procedure
- Investment product selection and portfolio construction
- Healthcare, CPAM and mutuelle questions
Articles reviewed by Vincent Berthier De Bortoli
Should You Even Move to France Right Now? A Wealthy American's Read on the 2026 Wealth-Tax Debate and Political Risk
The 2% tax on fortunes above 100 million euros is not in the 2026 Finance Law. What passed: a 20% levy on luxury assets in family holdings. IFI unchanged.
French Inheritance Law for Americans: Forced Heirship, Brussels IV, and the Estate Tax Treaty Explained (2026)
How French forced heirship, Brussels IV, and the US-France estate tax treaty affect Americans in France, plus 2026 succession tax rates.
First-time filing French income taxes as an American? Numéro fiscal, Form 2042, Form 2047, deadlines by department, and declaring US income explained.
IFI Explained for Americans: France's Real Estate Wealth Tax and the 5-Year Grace Period
France's IFI taxes real estate wealth above 1.3 million euros. New arrivals get a 5-year exemption on foreign property. What US movers need to know.
Disclosure
VBDB Tax Attorney is a partner of EasyFranceNow. Vincent Berthier De Bortoli reviews selected articles for factual accuracy. He does not write our content, has no editorial control over our recommendations, and is not paid for these reviews.
Vincent Berthier De Bortoli does not write our content and has no editorial control over our recommendations. A review confirms a guide is factually accurate in general; it is not financial, tax or legal advice for your situation. How our review process works.
Think something on a reviewed guide is wrong? Tell us , we check it, fix it if you are right, and send it back for review.
Read the guides they checked.
Guides for Americans in France on us taxes abroad, first steps. Free, sourced, dated, and reviewed on these topics.





