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Talking Expat Taxes #21

The France Property Rule Nobody Tells Americans

Americans who buy in Europe tend to arrive with an American mental model: my agent, their agent, my lawyer, their lawyer, title insurance, closing. France doesn't work that way - and neither do Italy, Spain, Portugal, or Greece. In this episode, Alex McGowin sits down with Alexandre Ghasarossian of European Private Office in Paris, who spent seven years in M&A at Rothschild & Co before pointing that same coordination work at North American families buying homes and relocating across Europe. His starting premise is that the country is the answer, not the question, and he walks through the five-part framework he uses to get there: life, clock, people, money, and exit. From there the conversation gets specific. Why the Schengen 90/180 rule counts across the whole zone rather than per country, and how that strands people mid-renovation or past a September school deadline. Why French administration isn't hostile so much as sequential - including the loop where the bank wants residency and residency wants a bank. How France treats a retiree's pension and healthcare, why a US LLC or a trust is often the wrong vehicle once you're a French resident, and the buyer protection almost no American knows exists: you can appoint your own notaire alongside the seller's, and it costs you nothing. Alexandre works across France, Italy, Spain, Portugal, Greece, and Monaco. Find him at europeanprivateoffice.com.

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Show Notes

The country is the answer, not the question. I'd start with the life you're trying to build.

Takeaways

  • Start with the life, not the map.

    Alexandre's five questions - life, clock, people, money, exit - settle the country as an output, not a starting guess.

  • The 90/180 rule is Schengen-wide.

    Hopping France to Italy resets nothing, and overstaying quietly damages a later residency application.

You're the general contractor of your own life, at a distance, in a language you don't speak.

Today's Guest
Alexandre Ghasarossian

Alexandre Ghasarossian

Alexandre Ghasarossian is the founder of European Private Office, a Paris-based firm that coordinates home purchases and relocations across France, Italy, Spain, Portugal, Greece, and Monaco for North American families. He spent seven years in M&A at Rothschild & Co, working large-cap technology transactions, before moving into European real estate investment at MidCrest. European Private Office exists to fill a gap he kept seeing: clients with excellent individual advisors but no one owning the European project as a whole. europeanprivateoffice.com

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00:00:00Alex

TET 21 === Welcome to another episode of Talking Expat Taxes. My name's Alex McGowin, owner of McGowin Tax, where we help individuals and small businesses solve international tax problems, comply with their international taxes, save taxes, and ultimately make better financial decisions. As we've talked about many times on this podcast, taxes, finance side, that is a, a piece, maybe a big piece, but a piece of the overall puzzle when you're trying to move abroad or maybe just investing abroad.

00:00:34Alex

As an expat, planning to be an expat, there's a lot of things you need to take into consideration. One of them is US taxes, the other is everything else, right? The taxes in the local country, how that's going to coordinate with the US taxes, planning for housing, schooling, all the things.

00:00:52Alex

So today, very fortunate to have on, Alex, who is also has a great name, so we know he's gonna be super smart, with a name like that. And so, but, uh, but yeah, he, um... So Alex is, you know, I'm gonna let him give his background on, what he does, his company, and what they can do, but it's really looking at the European side of moving outside the US really appreciate it. Uh, yeah, thanks for coming on.

00:01:19Alexandre

Thank you for invitation. Thank you for this podcast.

Meet Alexandre and His Mission

00:01:22Alexandre

So I'm Alexandre. I run European Private Office. I'm French, as you can recognize with my accent, based in Paris, and we work with, North American families who want to buy a home in Europe or actually move here. And my background is, M&A and European real estate investing. A lot of that work is, taking a complicated situation with, lawyer, banks, and advisor and making sure everyone is moving toward the same, outcome. And what I kept, seeing with family going to Europe is that they had excellent individual advisor, and still nobody owned, the European project as a whole. And that's the job I do. And, actually, when we first, spoke, you said something that stuck with me, uh, about France and Italy have been, two of the hardest places for you to find a professional, you really trust.

00:02:20Alexandre

And that's a big part of why I wanted to do this, one with you. And if that's still how it looks from your side

00:02:28Alex

Yeah.

Why Expats Need a Coordinator

00:02:29Alex

No, that's a great point. I work with people moving all over the place, but, my clients have moved to Costa Rica or the UK or Australia. Over the years I've, I definitely have found partners in a lot of countries that can help with local taxes, local immigration, things like that.

00:02:46Alex

I work with people in France and Italy, but, I would say those two countries I've had the hardest time, like nailing down, good professional advisors that I know and trust, which is kind of what, what intrigued me about, your company and what you do 'cause, a lot of what you're doing is playing, I like to make sports analogies, but like coach and quarterback at the same time, right?

00:03:08Alex

Stepping back real quick, so your background is in more of the financial side of people making investment decisions, like in the M&A side, a- and then you saw a gap in there. Tell, talk a little bit about that, how like your original experience

From M&A to European Moves

00:03:23Alexandre

I can talk about how did I get into this. I spent, years in M&A, then, uh, underwriting real estate, across Europe.

00:03:34Alexandre

And

00:03:34Alex

So just to be, just to be clear what you mean by that, you mean like a, company that's acquiring another company

00:03:41Alexandre

Exactly. Exactly.

00:03:43Alex

in another company

00:03:44Alexandre

Yeah, I, I work during seven years, at Rothschild & Co. In the large cap team in France, mostly, tech deals. And I help, top companies to acquire, uh, companies in Europe or even in the US.

00:04:01Alex

Right

00:04:03Alexandre

and most of this job is coordination between all the advisor, and during the process of, the idea of it could-- can-- it could be a good idea to buy this company to the closing of a deal.

00:04:21Alexandre

And of course, you have to interact with a lot of advisor. And what it's a bit crazy when you think about it, it's basically you are taking... Because as I was focusing on the biggest deals, of course you can take the big, the maybe the best advisor on the place. But even with that, you need someone to coordinate the deal, to coordinate all the counterparties. And I think it's even more, uh, important for international deals, with two countries. And then I started watching Americans, uh, do, European projects, and it was the same structure with none of the coordination. A great tax advisor like Alex in the US, uh, a lawyer somewhere, an agent in the country, and the client in the middle, being the general contractor of their own life at a distance, in a language they don't speak.

00:05:22Alex

Yeah. Okay. Yeah, it makes sense. You were dealing for very heavy financial deals, understanding the, talking to the right people, translating it either literally from a language perspective, but translating it into actionable items, practable, practical steps for people, getting them from the beginning to the end of the process.

00:05:42Alex

So I'm curious, like from there, now what you're doing is a similar type of guidance, less financially heavy, right? I mean, that's gonna be part of it, but now it's more of a coordination. I'm curious, like what did you see in what you were doing that like you saw this gap and need out there?

00:06:02Alex

'Cause I definitely see it, but I'm just curious from your side, where did you see this gap? Was it part of what you were doing? Was it more on a personal side that you knew people that were moving to France

00:06:11Alexandre

I think both, because my-- after watching & Co., I did, um, I work, in a company named MidCrest, and basically my job was to invest in real estate, uh, across Europe. And I discover, I think one of the most difficult parts, of buying a real estate piece in different countries. country has its own rules, uh, and it's really easy to miss a part. And if you add this, if you add on top of this the visa, uh, tax,

00:06:48Alexandre

Of course your daily life, it's very difficult to, do these type of things, this type of move without someone.

00:06:56Alex

Right. Yeah, for sure. I see it every day. I get people come to me with tax questions, but that's usually, like I mentioned at the beginning of the podcast, it was, it's a piece of the overall puzzle, and it's very complicated to, to do it all yourself, you know? And I mean, dangerous to some extent, because especially when you're dealing with a lot of money, it's one thing to,

00:07:21Alexandre

a- and during this podcast, I will give you some example, and it can be, yeah, it can be very dangerous if you

00:07:27Alexandre

do some mistakes. Because just you don't know these rules and you trust, uh, and yeah, at the end you are a bit screwed.

00:07:36Alex

Maybe let's start there. Like, let's, let's use me as an example. If I'm trying to, if I was interested in, let's say, broadly moving to Europe maybe we start there, the first step. It's like, "Hey, I'm, tired of the US, I wanna move to Europe. I don't really know where.

00:07:51Alex

I've heard that, I've heard Portugal has good, programs out there. I love the wine country of France and the bread or I just said it backwards. The wi- wine co- whatever, you know. I love Italy and France and, but I don't know where to go and what's more complicated and what's not.

00:08:06Alex

What's that first step of, like, helping somebody decide on a place?

A Real Client Move to Paris

00:08:11Alexandre

I think, uh, we can work through a typical client scenario, and maybe I can take you through a family I finished with a few weeks ago.

00:08:19Alexandre

So, uh, American couples in New York. He's around 40. Uh, just, just sold his tech company, wants to start the next one. Wife, uh, one child. They had been coming to Paris for years and had fallen in love with it. And they didn't come to me asking for an apartment. Uh, they came asking where to start, residence, how long they were even allowed to stay, tax on both side, property, French bank,

00:08:51Alexandre

moving the money, estate planning, uh, because they have a child, the administration. And yeah, and which of this you are supposed to do first.

00:09:00Alexandre

And, we work through it in order. They came in wanting, to rent and end up, buying, two million euros, about 150 square meters, call it, uh, 1,600 square feet,

00:09:15Alexandre

uh, in the 16th. Local French financing, then full renovation, and he move in last week. Um, and yes, I think, he didn't need a, another advisor. He needed someone to own, uh, the European side, so he could go build his next company without thinking about, all this stuff, basically.

00:09:41Alex

Yeah. No, that makes sense. So in that scenario, 'cause you're not a lawyer, you're not an accountant, you know, so you're not taking people through immigration process. So is literally what you're doing is you're connecting them with immigration people, realtors, and things like that and helping them close on real estate?

00:10:00Alex

Are you involved personally in all of the communication

00:10:03Alexandre

Yeah, I'm involved personally on all the cases. Of course, based on the, on your experience, we can give some general concept, general advice.

00:10:15Alexandre

But of course, each case is very specific, and we coordinate all the advisor.

Choosing a Country Framework

00:10:25Alexandre

But for answering your question about, okay, if you want-- if you hesitate between France, Italy, Portugal, I think the country-- I wouldn't start with the country.

00:10:33Alexandre

The country is the answer, not the question. Yeah, I would start with the life you're trying to build, because the, yeah, the country is the answer. And I ask five things generally. So what I say is life, clock, people, money, and exit. So I will explain.

00:10:51Alexandre

Life is basically, what does an ordinary Tues-Tuesday look like? A city that works in February or a view in July. It's, of course, it's totally different. Clock is how many months, how many months a year and in what pattern?

00:11:08Alexandre

Who visits how often? How hard is it for them? Uh, children, grandchildren, parents back home, business partners. Of course, it's totally different, if you choose an apartment, for example, in Paris, you're well connected to the US, so it's really easy to move from a place to another.

00:11:28Alexandre

If you take a small city in the south of France without an international airport. You know, it's, it looks a bit obvious when you think about it, but, you know, I can see a lot of cases of people like: "Oh yeah, I love this place. Each year I spend, let's, I spend two months, and I love this place, and I would like to stay, there for eight months a year." Yes, but maybe for your life it doesn't work. It's not linked to an international airport. It will be very difficult. If you want to move your old parents, it will be challenging. You know, it's lot of question that you, you need to think about, and that's why people, I think it's the third, uh, word of this framework. Then, of course, the money,

00:12:13Alexandre

and, uh, cost to build, cost to hold, and what tax, and I think it's your specialty, uh, and estates make of it. And then the final one is exit. If you're wrong and in three years, and what does it cost to get out? And if you're right in 30, what happens to it when you die? Uh, so it's important to think about the inheritance, and we'll discuss this after. But yeah, I think it's the five, word for my, let's say, my framework for discussing about, okay, what is the best country for you?

00:12:49Alex

Right. Yeah, I think that's a great way to frame it. Um, it's obviously gonna depend, and it's a decision that people have to make personally based on what they want. But I think the exit one particularly is interesting and important. I spend a lot of time in Costa Rica and work with people there, and it just came to my mind.

00:13:07Alex

A lot of times what happens down there, people love vacationing there, and they go to the beach. And so they're like, "I wanna buy at the beach." And then they buy down there, and they move there, and a lot of people end up going to the mountains because the beach is very touristy. And, you know, and people, as you spend more time there, it's like you're not vacationing anymore.

00:13:27Alex

You wanna be, you want a home that's, you know, then you... Yeah, exactly. So, and it could be the same. It made me think when you were talking about France, people love going out to the wine country or going down to the south of France, but actually living there is a different scenario. It's not gonna have the same amenities that a, a Paris would have, obviously, or a bigger city, you know, in general.

00:13:51Alexandre

Yeah. No, no, it's, it's totally different, and that's why of course, depending on your wealth. For example, one of the couple, one of my clients has decided to buy two houses,

00:14:00Alexandre

one close to Paris and one in the south. Of course,

00:14:04Alexandre

it

00:14:04Alex

Let's...

00:14:04Alexandre

problem. But

00:14:06Alex

right

00:14:06Alexandre

that, no, no, of course, it's, it's really important to think about it.

France vs Italy vs Portugal

00:14:09Alexandre

And when you think about the three countries, so France, Italy, Portugal, I think if I summarize them, I think what they are generally good at, for France, I think everything works all year. I think it's the best connectivity to the US. Paris is the easiest place in Europe to get home from. Um, real healthcare outside the big cities, high-speed rail, so you are not trapped by one airport in a lot of places, because it's really easy to, to go from a place to another. I think it's easily standard-standardized, notary-led purchase process. And I will explain what is it and all the,

00:14:51Alexandre

the specificity about that, after. But that's the notary-led purchase process that protects a foreign buyer, more than people expect.

00:15:00Alexandre

And I think on the underestimated aspect of France, I can say the administration is-- now the administration isn't hostile, but let's say it's sequential.

00:15:12Alexandre

Uh, every doors needs the documents from the previous door and, and buying cost are real, uh, about uh, seven percent, seven to eight percent

00:15:24Alex

What kind

00:15:24Alexandre

an

00:15:24Alex

costs? Say that again

00:15:27Alexandre

When

00:15:27Alexandre

you buy, Uh

00:15:28Alexandre

a real estate apartment, when you buy an apartment or house, the transfer cost

00:15:34Alex

Oh,

00:15:34Alexandre

is between 7% to 8%,

00:15:37Alex

Okay. I understand

00:15:38Alexandre

on an older property.

00:15:40Alex

Okay

00:15:41Alexandre

it's mostly transfer tax. The notary basically takes 0.5% to support you in this transaction.

00:15:49Alex

Okay. Under-

00:15:52Alexandre

but we will discuss this after in, uh, in the re- in the acquisition topic.

Picking Cities and Real Examples

00:15:57Alex

Earlier you mentioned, like, with your client that they knew they wanted to be in France, but they knew there was all these things, residency, real estate. What was the first step for them? Was it residency and visas and immigration? Was it real estate? Do you kinda do some at the same time ideally, I guess?

00:16:16Alexandre

Yes. I think for generally my first job is to support the choice of a place. Uh, to just, you know, to confirm that it's the right decision to continue, um, this process and this transaction. So generally I help them to choose between the cities. So for example, if I take my New York couple, uh, were torn between, uh, Paris and, uh, something in the south. And the south, you know, is a, is a real tem-temptation.

00:16:47Alexandre

Sun, space, a much bigger house for the money. So we looked at actual places, but not just what you can buy and for how much, or would they really use it often, are they flying, which airport, uh, is there a direct flight to New York? Or does every trips, become a connection? Can family get there without an expedition? Is it alive in February? It's really important point, but a lot of cities in France in February, it's totally different from August or July in term of, of lifestyle, in term of restaurant, in term of places where you can go.

00:17:29Alex

Oh, you mean so like if it's a more touristy place, you mean in February everything might be closed?

00:17:34Alexandre

Exactly. For example, like if you take Cannes. Cannes, it's, you know, for the movie, uh, you-- it's very active, during the summer, but in

00:17:43Alexandre

February it's,

00:17:45Alexandre

There's no one. So if you buy an apartment in this place and you want to live during the full year,

00:17:54Alexandre

February will be a bit challenging, let's

00:17:56Alex

Yeah, it may not be what you're expecting

00:17:59Alexandre

exactly. And of course, you don't think about this sometimes when you, you buy, a place.

00:18:05Alexandre

And yes, and what does it take to rent a big property with a garden when you're five thousand miles away eight months a year?

00:18:14Alexandre

And put that way, Paris won on their own criteria,

00:18:19Alexandre

a bit like the mountain with your example, and they already know the city. They arrive and life works immediately. People come to them, and there is no, house sitting empty needing a person.

00:18:33Alex

Yeah, understood

00:18:34Alexandre

And if I take, for example, another case, completely different, uh, couple, retired around 75, Dallas.

00:18:43Alexandre

Italian family on one side, children and grandchildren. They were hesitating between south of France or Italy. And on the paper, the south of France was the easier answer.

00:18:55Alexandre

But they were, you know, they weren't optimizing a spreadsheet, if I take this parallel with finance.

00:19:01Alexandre

They were trying to build a place, their children and grandchildren would actually want to come back to. And the Italian side, was where the family story was.

00:19:12Alex

Makes sense

00:19:13Alexandre

when you think about it, so Italy wasn't the sentimental choice over the rational one. Once you know what the house is for, it was the rational one

00:19:22Alex

Right. That makes sense

00:19:24Alexandre

And, uh, for example, this couple, they end up in, Arcetri on the hill, uh, just south of Florence. Historic, uh, villino, 4,300 square feet, wall garden, a gate, the walled city under the window, and 10 minute from Florence.

00:19:42Alex

Yeah

00:19:43Alexandre

So yeah, it was, it was a good choice for them

00:19:46Alex

Yeah, that makes sense. I mean, the first step I agree is making sure, or at least, you know, to some extent, moving to another country is always going to be a leap of faith, right? I mean, you can never be 100% sure about something you don't know, 100% about.

00:20:03Alex

I mean, of course, spending time in the places is the obvious best way for you to understand if it's good for you. But realistically, it would take you years of spending time in different places to understand everything about what makes it right or wrong.

00:20:20Alex

So having people like you, having people on the ground to give those insights. Like, maybe you haven't been to Cannes in, in February, and they don't have to experience that. You can just tell them, "Hey, all those restaurants that you love in July, they're not open in, from, for two months

00:20:37Alex

you know? Understanding and knowing that.

Next Up France Residency Visas

00:20:40Alex

So yeah, I agree, but let's say, yeah, let's move on to, like, the more technical side of it. So once, once we decide where we wanna be, I'm interested in France in particular, cause I have some clients, in France who have...

00:20:52Alex

I mean, you mentioned the bureaucracy a little bit in France, and how do I say this? People have complained, let's put it that way, about, about, like, the process. And part of that is them trying to do it themselves, to be honest with you. They're just showing up places to, to apply for a visa and then finding out, well, the place they went, there's nobody there that speaks English, and they had a really hard time, navigating the process from a language perspective or whatever it may be.

00:21:24Alex

I guess, let's start, what are your options from a residency perspective in France, and what, what do you recommend? How do people navigate through it? Let's talk a little bit about residency.

00:21:38Alex

And maybe visas. I don't know. They kind of go hand in hand, right? But yeah.

00:21:42Alexandre

Of course. Um, and that's why I put administration in the in the negative aspect in France.

00:21:50Alexandre

Uh,

Schengen 90/180 Rule

00:21:51Alex

I guess let's keep it from the perspective of a US person, 'cause it can be different depending

00:21:56Alexandre

I think the important rule, it's a US passport give 90 days in any rolling 180 across Schengen. So it's Schengen wide. It's not per country. So hopping France to Italy resents, reset nothing. It's not like in Eas- in Asia, for example, where you can just go in another country just for one day

00:22:20Alexandre

and then coming back and it reset. It's not like this. It's,

00:22:25Alexandre

it's v- it's Schengen wide.

00:22:26Alex

So just to make the math easy, you have 90 days in France or in the Schengen Area in general, and then you have to go outside of that whole Schengen area, so maybe back to the US or

00:22:39Alex

or somewhere and you have to spend 180 days outside before you can go back? Or is it 90? Oh, a rolling 180, so you have another

00:22:47Alexandre

annual rolling. Yeah, exactly.

00:22:48Alexandre

Exactly. Exactly. So of course it depends. So for example, for the couple, in New York, as it's only for summer and Christmas, it's not a big issue. Um, but if you want to stay, you need to apply for a visa. It's not-- Let's say it's not difficult or challenging for a wealthy US family. The threshold of revenue/wealth are not really high.

00:23:20Alex

Yeah

00:23:21Alexandre

they are very low, if I want to be fair.

Visa Timing Pitfalls

00:23:23Alexandre

But what is difficult, it's exactly what you said. It's no one is speaking English or few.

00:23:30Alexandre

Uh, it's very difficult to challenge. It's long. And sometimes, you know, it's the, um, it's very diff... It's the impossible loop.

00:23:40Alexandre

It's like they ask you, for example, for a French bank account, but you can't have a French bank account if you don't have a residency. So and you can't have, uh, the, this, real estate, uh, acquisition if you don't have this. So, and it's a nightmare. And that's why I said it's, they are not hostile, but it's sequential. It's really important to have the right sequence and it's very specific to each case. Sometimes you have to begin with, with a visa. Sometimes you have to start with the real estate acquisitions. And yeah, it's specific

00:24:16Alex

Right. Yeah, no, that makes sense.

Residency Options Overview

00:24:18Alex

Do you find that a lot of your clients, they're looking for a residency option? That, like, that's a big piece of it, is getting a second residency? You know, people call it plan B to have a, place to go. 'Cause, 'cause a lot of times, I mean, 90 days, that's a vacationer, right?

00:24:35Alex

Like,

00:24:35Alex

if you're, if you're wanting to have a place in south of France, you can spend a few weeks a year, maybe a couple months, that, then you don't have to worry about that. But if you're going somewhere, if you want to be able to spend half the year in these places, and, 'cause I think that rule...

00:24:49Alex

Is the rule the same, the nine- the 180 rolling day in Italy, uh, Portugal?

00:24:56Alexandre

it's for the Schengen area,

00:24:57Alexandre

yeah

00:24:57Alex

So yeah, that's the first distinction is one of your thing was the clock, right? One of your five. So, like, how many... Like, how long are you now staying there? So yeah, if, if you're trying to move there, residency is required really.

00:25:11Alexandre

Exactly. And it's-- as I said, it's not difficult generally. It's between three to maximum six months, to obtain. So it's, it's of course, it's recommended if you want to acquire something quickly, it's recommended to take care of this aspect before.

00:25:26Alex

Can you do it before you move

00:25:27Alexandre

Yeah. Yeah, yeah,

00:25:28Alex

If I wanted to,

00:25:29Alex

let's say my kids are gonna be in college in 10 years, and I'd like to go ahead and get, French residency, go ahead and start the process. What, what are my options to get residency before moving?

Planning Visas Early

00:25:43Alexandre

Of course, it's depending on your cases. Uh, for example, there is a specific visa for retiree.

00:25:50Alexandre

If you are 70 and, uh, you have a pension, it's really easy to come in Paris, and to buy an apartment. You have a specific visa for that. If you are an entrepreneur, you have another visa for that. So of course, it depends. But generally, as I say, it's not so difficult, but you need to plan this before. For example, I have two example, of people that I know. They are not my clients. But, someone, uh, bought, an apartment, and they planned a lot of renovation in his apartment

00:26:24Alexandre

and discover the 90 days, uh, rule. Uh, and so he was blocked in his renovation because, of course, he couldn't, you know, handle all the stuff at 5,000 miles away. So big problems. Another person, they planned, um, a move with their kid. And in France, the school start in September, so if you miss the deadline of the visa and you are blocked in the US

00:27:03Alex

Ah, then you miss the whole school year.

00:27:05Alex

Yeah, it makes sense.

Overstays and Consequences

00:27:06Alex

How strict is France on that 90-day rule?

00:27:11Alexandre

It's not like the US,

00:27:12Alex

Okay.

00:27:13Alexandre

if you want a comparison. It's not like the

00:27:14Alexandre

US. They are not, uh, rude and strict as the US,

00:27:19Alex

Okay

00:27:20Alexandre

but, you know, I think it's

00:27:22Alex

It's a risk you don't necessarily want to accidentally you don't ac- you don't accidentally end up in, in French prison, you know? Uh

00:27:31Alexandre

No, I, I-- you, you won't go in prison for that, but it's more like, for example, if you want after the full residency, if you want to stay and you have this...

00:27:42Alex

It's not gonna look good. It's gonna make it hard.

00:27:45Alexandre

It won't help you. So you will need to pay your lawyer more for solving

00:27:49Alexandre

this issue.

00:27:50Alex

That's a, yeah, it's an expensive mistake at the very least.

00:27:54Alexandre

Exactly. So no, it's...

Residency Process Steps

00:27:55Alex

so what is the process there? Like, for, for a client, you know, if I was trying to get residency, let's say, I, I guess it depends on the type of residency or visa you're going after, but you get them connected with an immigration attorney and that helps, and then they walk them through the process?

00:28:12Alexandre

Exactly. Uh, I think first we decide, uh, the life and the months.

00:28:17Alexandre

So how many months a year, in what pattern? Because for example, the New York couple doesn't need this visa when you think about it. So, you know, if you can, if you can miss this, it's, it's better.

00:28:30Alex

Not gonna spend more than 90 days, then you can just use your US passport and you're good

00:28:35Alexandre

If you can just use your US passport and it works, why do you want to apply for a visa to take someone to help you? If they need more, we identify the long stay route, uh, before moving. So depending on the case, we can handle the process for them or with an immigration lawyer. From the US, uh, on a calendar, not after, arrival, uh, as I said, is better.

Tax Implications by Profile

00:29:05Alexandre

And then, What is very important, it's your aspect, it's, uh, the same plan that works for immigration may look very different from a tax perspective

00:29:17Alex

Yeah, that was gonna be my next question is, I know you're not, y- you know, a tax lawyer, but I mean, When is residency generally triggered in, France from a tax perspective?

00:29:35Alexandre

From a tax perspective, it's, very different depending on the profile. For example, I take, uh, the retiree couple. They have a very, very nice, conditions in term of tax, for retired people in France. Uh, for example, they are not taxed on their pension.

00:29:56Alexandre

Are only taxed in the US. exactly. Uh, the healthcare is free

00:30:03Alex

Yeah.

00:30:04Alexandre

Totally free.

00:30:05Alex

Yeah

00:30:06Alexandre

Generally nice when you're a bit old and you have a lot of, uh, healthcare ex- expense.

00:30:11Alex

And that's under the retiree visa residency. So these are permanent residents at this point

00:30:18Alexandre

When you're a French resident after three months, it's like this. You don't pay for the healthcare. You are not taxed on the pensions. So of course, you need to have a proper visa. But if you have a right visa, if everything is under well, you don't pay anything in term of on your pension, on the healthcare. Uh, of course, if you buy an apartment, you have to pay the transfer taxes,

00:30:52Alexandre

uh, and you have to pay all the local taxes linked to the real estate and stuff.

00:30:56Alexandre

But on other aspect, you don't pay.

Structuring Businesses and Trusts

00:30:59Alexandre

When you are an entrepreneur, it's of course, it depends on your structure. So for example, if it's a, a US LLC, as you know, it's, it's a transparent structure. So if you have a French residency, it's not the best in term of optimization, and I don't recommend, for example, the US LLC, in France. Or of course depend-- You have to structure it maybe differently, uh, if you want to have a full residency in France, if you want to live in France full-time, because it will have a lot of, of impact

00:31:39Alex

Right. Yeah, it's definitely gonna be different for an entrepreneur. I would just say if you're moving to France, Italy, any- basically anywhere in Europe, you're not doing it to save taxes if you're a US person. No, that, that's not the, that's not... You're gonna be disappointed if, if that's your, if that's your goal.

00:31:59Alex

But you can make it worse than it needs to be by not structuring things correctly. It's important to make things efficient, which the only way to make things efficient is to understand what the implication is in the first place and plan for it accordingly. You're not gonna pay less taxes at the end of the day if you're following rules, but you're not gonna unnecessarily...

00:32:24Alex

I mean, it's always a balance, right? It's structure things efficiently to reduce your taxes to a legal amount. But at the same time, don't overly complicate your structure unless there's actual value to doing so. You know, a lot of people come to me with setting up trusts and companies and French, French SAs and all these things, but the first step is, I mean, kind of like we talked about before with like the moving concept is what is the value of doing this and does it really make sense?

00:32:57Alex

Um, in a lot of cases it doesn't. Like a lot

00:32:59Alexandre

E-exactly. And, and sometimes you need to know, for example, a trust doesn't work in France. So if you buy, for example, if you have a trust and you want to buy, an apartment with your trust, it doesn't work well. So you should, for example, in this case, focus on a more local, structure, or maybe you can use your normal structure.

00:33:19Alexandre

But for example, in this case, for France, it doesn't work. So yeah, that's why sometimes when you want to overcomplicate things

00:33:30Alex

For sure.

Countries Served and Wrap-Up

00:33:31Alex

So in general, like what, what countries if I was to come to you, what countries are you able to help with, do you focus on with your business?

00:33:41Alexandre

Spain, Portugal, Italy, France, Greece, and Monaco. Uh, the framework doesn't change, only the local execution does

00:33:51Alex

Very good. Well, look, this is very interesting stuff. The business you've put together is definitely one where I see a huge need in the market. I mean, people moving to Europe has been and always will be, a thing, and it's not that... It's not a simple thing to try and do yourself. In a lot of cases, there's more information out there, than there's ever been.

00:34:13Alex

But that almost makes it worse because , it makes it more complicated 'cause you have all this information to read through and decipher and, every situation's not the same. That's the point, I think, is that every situation's gonna be unique to that person, and that's where somebody like you and your team can definitely help put people in the right place, avoid costly mistakes, and get where you wanna be.

00:34:36Alex

If we could maybe wrap up with are there any specific mistakes that you see people make that people should be aware of?

French Real Estate Gotchas

00:34:45Alexandre

I, I think, uh, Americans arrive with an American mo-mental model. Uh, for example, for real estate, my agent, their agent, my lawyer, their lawyer, uh,

00:34:56Alexandre

title insurance, closing. But France, uh, doesn't work that way. The agent is, normally instructed by the seller. A dedicated buyer's agent exist but isn't the norm. Uh, and the transaction run through a notaire, who is a public officer with a duty to the transaction itself, not an advocate for one side. And here is where almost, uh, no American knows, uh, you can appoint your own notaire alongside the sellers.

00:35:27Alex

And you're saying notary like a notary, that's what you're

00:35:29Alexandre

Yeah, like the notary. Yeah, sorry. Notaire, it's the French word for

00:35:33Alexandre

notary. Exactly. Uh, but it's, it's totally different from the notary that you know in the

00:35:39Alex

yeah, the US notary is it's a very limited thing that

00:35:44Alexandre

In France, it's mandatory. So if you buy, uh, an apartment or a house, you need to have a notary.

00:35:51Alex

Mm-hmm.

00:35:53Alexandre

And yeah, it's a public officer, will basically check the transaction. And the problem of that, it's-- And what I said is almost no American knows that you can appoint your own notary alongside the seller. So two notaires, two notaries, and they share one set of regulated fees. The buyer doesn't pay twice. And I'm not saying the seller or notaire does a bad job, uh, that isn't how the profession works. But I'm saying that if you're a foreigner, if you're a foreign buying in a language that you don't read, having someone in that room who's file you or, and who's question or your question cost you nothing. Yeah, people spend two millions euros and never find out the option exists. And you know, I have a case, for example, because agents, for example, right, and it's really important to know and understand it. Real estate agents in France or in Europe in general, they are totally, different from the agents that you know in the US.

00:36:56Alexandre

Uh, if they hide you some information, you can sue them. In France, in Europe, it's very difficult. So imagine as the agent is, hired by the seller, as the notary is linked to the seller

00:37:12Alex

Okay

00:37:13Alexandre

You know, if the notary is a friend,

00:37:18Alex

Right

00:37:18Alexandre

just want is a transaction fee. They can hide you some information. And if you don't have someone to inspect, to check everything, imagine for example, , the, real estate the building has decided, uh, to launch a huge renovation work,

00:37:39Alex

Mm-hmm

00:37:39Alexandre

In 12 months. It will cost you, uh, I don't know, 200,000 euros And you don't know about this. So you know, you will-- you won't adjust your price because you don't know about this renovation.

00:37:54Alex

Right

00:37:55Alexandre

And if you don't have someone who will read the 300 pages of all the reports, of all the discussion about the renovations and flag this,

00:38:07Alexandre

of course, they don't have... it's not mandatory to flag, to flag you this information. And if the notary is linked to the seller

00:38:15Alex

Right. And you can't blame, you can't blame ChatGPT later if it didn't point it out to you when you put it

00:38:21Alexandre

Exactly. Exactly. Of course.

00:38:24Alex

Yeah. Yeah. I mean, have somebody in your corner, on your side. And like you said, I wouldn't know that it's even an option to get my own notary, unless somebody tells me that, so.

00:38:34Alexandre

And it's free. It doesn't cost you more.

00:38:37Alex

Yeah. Oh, because they share the fee. I understand. Yeah, yeah. Okay. Interesting

Notaire Protections and Cooling-Off

00:38:42Alexandre

In France, for example, once you sign, the preliminary contract, uh, you get 10 days to walk away. No reason needed, no penalty. And on top of that, if you need a mortgage and you say so in the contract, the sale is legally conditional on you getting it. So if a banks turns you down, the deal stop and your deposit come back. And it's not something you have to negotiate in, it's the default, and you actually have to write it out by hand if you want to give it up.

Final Advice and Contact

00:39:19Alex

I would say that's probably like real estate makes me the most nervous. Even when I'm doing it in a, in the US and locally where I live, it's very complicated in your own language, much less somebody else's language, a different culture, a whole different...

00:39:34Alex

And the legal system is, is totally different in France, obviously. So yeah, no question, you need somebody advocating on your side with real estate deals. If nothing, if you have no other help, real estate is definitely one you need. But across the board, having a coach, having an advisor help you find the place, help you walk through the details, it's gonna save you, it's gonna save you a lot of time at the very least. What's the best way for people to find you and reach out to you if they wanna work with you?

00:40:06Alexandre

Yeah, I think the best way to reach me, it's on my website, uh, so europeanprivateoffice.com.

00:40:12Alex

Very good. Yeah, and I'll definitely leave links to your website and to your contact in the description to the show and, I appreciate you coming on. Let's, uh, let's stay in touch, and we'll definitely, we'll definitely be working together with mutual clients 'cause we're in the same, same world together, so

00:40:28Alexandre

Of course.

Thanks for your interest! 🎙️

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