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and Partners
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In-depth analysis and commentary on European investment markets, tax developments, and regulatory changes affecting U.S. investors.

Featured Article
Tax Advisory · March 2026

FATCA & FBAR: What U.S. Investors Must Know Before Buying European Property

A comprehensive guide to U.S. reporting obligations for Americans investing in European real estate — covering FBAR thresholds, Form 8938 requirements, PFIC considerations, and strategies to remain fully compliant while optimizing your tax position.

12 min read
Key Takeaways
  • FBAR filing required if aggregate foreign account balances exceed $10,000 at any point during the year
  • Form 8938 (FATCA) thresholds: $50,000 for U.S. residents, $200,000 for Americans abroad
  • European property held through a foreign entity may trigger PFIC or CFC rules
  • Rental income from European property is taxable in both the U.S. and the host country — treaties can reduce double taxation
  • Failure to file FBAR carries penalties up to $10,000 per violation (non-willful) or $100,000+ (willful)
C&A and Partners Tax Team
Cross-Border Tax Advisory
Real Estate
Tax Strategy
February 2026

Portugal's NHR Regime: The Ultimate Tax Advantage for U.S. Investors

Portugal's Non-Habitual Resident regime offers a 10% flat tax rate for 10 years — one of the most attractive tax regimes in the developed world. We analyze who qualifies, how to apply, and how to combine it with Golden Visa residency.

10% flat tax on qualifying foreign-source income for 10 consecutive years
Pension income taxed at 10% (reduced from the previous 0% following 2020 reform)
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10 min read
Company Formation
Structuring
January 2026

Setting Up a European Holding Company: Luxembourg vs Netherlands vs Ireland

A detailed comparison of Europe's three premier holding company jurisdictions — analyzing tax treaties, participation exemptions, substance requirements, and practical considerations for U.S. investors structuring European investments.

Luxembourg: world's largest investment fund domicile, extensive treaty network, 0% withholding on qualifying dividends
Netherlands: participation exemption covers 100% of qualifying dividends and capital gains, strong U.S. treaty
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15 min read
Market Analysis
Market Report
December 2025

European Real Estate 2026: Where U.S. Capital Is Flowing

Our annual analysis of European real estate markets identifies the strongest opportunities for U.S. investors in 2026 — from Milan's luxury residential market to Lisbon's commercial sector and Spain's coastal tourism assets.

Milan luxury residential: prime yields of 3.2-3.8%, strong demand from UHNW international buyers
Lisbon commercial: vacancy rates below 5% in CBD, rental growth of 8-12% YoY
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18 min read
Tax Advisory
Tax Planning
November 2025

Double Taxation Treaties: How U.S. Investors Can Legally Minimize European Tax

A practical guide to leveraging U.S.-EU tax treaties to eliminate or reduce double taxation on dividends, interest, royalties, and capital gains from European investments.

The U.S. has tax treaties with all major EU member states — but treaty benefits must be actively claimed
Limitation on Benefits (LOB) clauses in U.S. treaties prevent treaty shopping by third-country investors
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11 min read
Compliance
Compliance Alert
October 2025

DAC6 and GILTI: The Compliance Challenges Facing U.S. Investors in Europe

Two major regulatory frameworks — the EU's DAC6 mandatory disclosure regime and the U.S. GILTI rules — create complex compliance obligations for Americans with European business interests. We explain what you need to know.

DAC6 requires intermediaries (and in some cases taxpayers) to report cross-border arrangements that meet certain 'hallmarks'
GILTI (Global Intangible Low-Taxed Income) taxes U.S. shareholders on the low-taxed income of their foreign corporations
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9 min read
Key Topics
Cross-Border TaxReal Estate MarketsCompany FormationCompliance UpdatesGolden Visa ProgramsEU Regulatory ChangesInvestment StrategyMarket Analysis

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