I have has a long email exchange recently with Andy Sirkin, and we agree to differ, although we are in accord on many points - I will be editing and publishing our exchanges as it touches on some very important points relating to Fractional ownership in France.

My personal experience is that if you create an offshore company to hold the shares of a French property company, you are makng big future problems for yourself with taxes - capital gains, corporation, personal and business taxes.

The point we agree on is that any rentals done by any of the owners must not be anything to do with the property company. My opinion is that this makes third party rentals (or exchanges) impossible without incurring tax liabilities.

His name is Andrew Sirken. I do not have a Paris contact number but you can easily find him on the Internet, he has written many papers on Fractionals or Interval ownership.

I would highly suggest you make a contact with him as you continue to research the viability of French Fractionals. It is important to us, as we would consider doing a “Fractional exchange” for 60 days of our Hawaii house for one in Paris. We don’t want to get ourselves into something that would have serious implications because of french tax rules.

Patricia Eachus