Decisions of the Council of State dated February 28, 2025

March 3

Last Friday, the Council of State issued several tax rulings concerning, in particular:

- The application of the Franco-American tax treaty in the case of a French tax resident who is a shareholder in a general partnership holding financial interests in a limited partnership, where the limited partnership sells real property and realizes a capital gain: Council of State, 9th and 10th Chambers, Feb. 28, 2025, No. 491788, Cited in the tables

- the circumstances under which a breach of attorney-client privilege affects the validity of the correction procedure: Council of State, 9th and 10th Chambers, Feb. 28, 2025, No. 486336, Cited in the tables

- The procedure to be followed whenadministration not to accept the taxpayer’s property tax return in the context of a rental value reassessment: CE, 9th and 10th Chambers, Feb. 28, 2025, No. 488375, Cited in the tables

United StatesGeneral partnershipLimited partnershipReal estateReal estate capital gainsAttorney-client privilegeAttorneyTax auditAmendment proceedingsProperty taxRental value reassessmentTax treaties

Paul Mispelon

Decisions of the Council of State dated February 28, 2025

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