No, you misunderstand. It's not enough to satisfy the "form" required of tax law--you must also satisfy a test of "substance." France would pierce through the transaction and treat the "management fee" as a French salary (which, in substance, it is) and haul the taxpayer off to jail for evading taxes.
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No, you misunderstand. It's not enough to satisfy the "form" required of tax law--you must also satisfy a test of "substance." France would pierce through the transaction and treat the "management fee" as a French salary (which, in substance, it is) and haul the taxpayer off to jail for evading taxes.