{"id":2116304,"date":"2026-09-04T10:05:04","date_gmt":"2026-09-04T08:05:04","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/09\/04\/uk-owner-taxe-fonciere-after-sale-challenge\/"},"modified":"2026-09-04T10:05:04","modified_gmt":"2026-09-04T08:05:04","slug":"uk-owner-taxe-fonciere-after-sale-challenge","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/09\/04\/uk-owner-taxe-fonciere-after-sale-challenge\/","title":{"rendered":"Sold Your French Property? Why a UK Owner Still Receives the Taxe Fonci\u00e8re Bill and How to Challenge It"},"content":{"rendered":"

If you sold a French house, flat or holiday home and a new taxe fonci\u00e8re<\/em> bill has nevertheless reached your address in Britain, the letter is not automatically proof that the French tax office has made an error. Taxe fonci\u00e8re<\/em> is the annual French property tax charged on property, and French law normally fixes the person liable by looking at the situation on 1 January of the tax year. The date on which the sale completed, the date on which you left France and your post-Brexit nationality status can therefore lead to different answers.<\/p>\n

There are two separate questions. First, who is legally liable to the French tax authority? Secondly, did the deed of sale require the buyer to reimburse all or part of the amount to the seller? A private prorata temporis<\/em> clause may shift the economic burden between the parties without changing the name of the taxpayer on the public record. Confusing those questions is the reason many British owners send the wrong request to the wrong person.<\/p>\n

This guide focuses on a property already sold, the annual bill that follows, the cadastral record, a correction or refund claim, the evidence to attach and a request to defer disputed payment. It does not cover the purchase process or French capital-gains tax. The legal position and official texts cited below were checked on 4 September 2026. The practical answer still depends on the sale date, the wording of the deed and the date on which the transfer was published in the French land register.<\/p>\n

I. Why am I still liable for French taxe fonci\u00e8re after selling my property?<\/h2>\n

A. Who pays taxe fonci\u00e8re in the year of a sale, and what does 1 January mean?<\/h3>\n

The starting point is the nature of the charge. Article 1380 of the French Code g\u00e9n\u00e9ral des imp\u00f4ts<\/em> (General Tax Code) states: La taxe fonci\u00e8re est \u00e9tablie annuellement sur les propri\u00e9t\u00e9s b\u00e2ties sises en France \u00e0 l’exception de celles qui en sont express\u00e9ment exon\u00e9r\u00e9es par les dispositions du pr\u00e9sent code.<\/q> In English, the tax is assessed annually on built property located in France, subject to express exemptions. The official text is available in Article 1380 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>.<\/p>\n

The next question is the identity of the taxpayer. Article 1400 of the same Code provides that every built or unbuilt property must be assessed in the name of the current owner. It uses the expression propri\u00e9taire actuel<\/em>, meaning the owner recognised for the tax assessment. You can read the operative wording in Article 1400 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>. The rule is connected to the property in France, not to the owner\u2019s British residence, passport or access to a French bank account.<\/p>\n

Article 1415 supplies the date test. It says: La taxe fonci\u00e8re sur les propri\u00e9t\u00e9s b\u00e2ties, la taxe fonci\u00e8re sur les propri\u00e9t\u00e9s non b\u00e2ties et la taxe d’habitation sur les r\u00e9sidences secondaires sont \u00e9tablies pour l’ann\u00e9e enti\u00e8re d’apr\u00e8s les faits existants au 1er janvier de l’ann\u00e9e de l’imposition.<\/q> The direct source is Article 1415 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>. The effect is often described as the \u201c1 January rule\u201d: the tax is established for the whole year by reference to the facts existing on that day.<\/p>\n

For a normal sale, apply the test in this order:<\/p>\n\n\n\n\n\n\n\n\n
Event<\/th>\nTax year affected<\/th>\nPerson normally liable to the tax authority<\/th>\n<\/tr>\n<\/thead>\n
You owned the property on 1 January and sold it in September<\/td>\nThe year of the September sale<\/td>\nYou remain the legal taxpayer for that year<\/td>\n<\/tr>\n
The sale completed before 1 January of the relevant year<\/td>\nThe following tax year<\/td>\nThe buyer should normally be the taxpayer, subject to proper publication and cadastral updating<\/td>\n<\/tr>\n
The deed was signed before 1 January but publication or the cadastral update was delayed<\/td>\nThe following tax year<\/td>\nThe tax record may still show the former owner, which requires an evidence-based correction request<\/td>\n<\/tr>\n
You bought and sold in the same calendar year<\/td>\nThat calendar year<\/td>\nThe owner on 1 January is normally liable for the full annual assessment<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

These examples explain why the date printed on the notice is not enough. A notice issued in October can relate to a year in which you owned the property on 1 January. Conversely, a notice addressed to you for a year after completion may be wrong if the sale took effect before that 1 January and the transfer was properly recorded. Always read the tax year, the property reference, the commune and the date of completion before deciding that the bill should be cancelled.<\/p>\n

The annual principle also means that a sale on 2 February does not usually divide the public tax bill between 1 January and 2 February. The seller was the owner on 1 January and remains liable for the year. A sale on 30 December can create the opposite practical result for the following year: the buyer is the owner on 1 January, although the public register may take time to reflect the transfer. The private completion statement may contain a different financial arrangement, but that is a second-stage question.<\/p>\n

A bill may also include the taxe d\u2019enl\u00e8vement des ordures m\u00e9nag\u00e8res<\/em> (TEOM), the charge connected with household-waste collection. TEOM is not identical to the property tax, even when it appears on the same notice. The deed may apportion it differently, and occupancy or rental arrangements can matter. Do not assume that a clause headed \u201ctaxes fonci\u00e8res\u201d automatically answers every line on the notice. Identify each component and ask what the deed actually says.<\/p>\n

Brexit does not create a special exemption for a British owner and does not transfer the tax to the United Kingdom. The relevant connection is ownership of French property and the domestic assessment date. Residence in the UK can make the administration, digital access and correspondence more difficult, but it does not replace the French rules. An owner living in London, Manchester or Edinburgh can be liable in exactly the same way as an owner living in France if the owner was in the relevant legal position on 1 January.<\/p>\n

There are limited reliefs for particular situations, but a sale is not itself a relief. For example, Article 1389 of the Code g\u00e9n\u00e9ral des imp\u00f4ts deals with a possible d\u00e9gr\u00e8vement<\/em>, meaning a reduction or cancellation of tax, where a qualifying property is vacant or a qualifying business property is no longer operated. The statutory conditions include a period of at least three months and circumstances independent of the taxpayer\u2019s will. The relevant official provision is in the Article 1389 section of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>. A property that has been sold is not simply treated as vacant for that reason.<\/p>\n

Similarly, a lower market value is not a reason to erase the tax automatically. The assessment base follows specific French valuation rules and local rates. If you dispute the valuation, the claim should identify the legal and factual error, rather than merely state that the property sold for less than expected. Article 1507 confirms that taxpayers may challenge the assessment assigned to a built property in the time and form provided by the tax-procedure rules; the text is available in Article 1507 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>.<\/p>\n

For a British owner, the first working conclusion is therefore simple: a post-sale notice can be perfectly consistent with French law when the sale occurred after 1 January. The useful next step is not to argue that the property is no longer yours today. It is to establish who owned it on 1 January of the tax year and whether the notice concerns that same property.<\/p>\n

B. Does a notarial prorata clause transfer the tax debt to the buyer?<\/h3>\n

French deeds commonly contain a private allocation of the annual tax. The wording may say that the buyer reimburses the seller for the part corresponding to the period after completion, or that the buyer bears the entire amount for the year. This is often called a prorata temporis<\/em> arrangement: the parties divide a yearly cost by time. It is an agreement between seller and buyer. It is not, by itself, an instruction binding the tax authority.<\/p>\n

Article 1103 of the French Civil Code states: Les contrats l\u00e9galement form\u00e9s tiennent lieu de loi \u00e0 ceux qui les ont faits.<\/q> The official version is available at Article 1103 of the Code civil<\/a>. The principle supports enforcement of a clear contractual promise, but the clause must be read in its actual context. A reference to \u201ccurrent charges\u201d may not have the same scope as an express promise to reimburse the annual taxe fonci\u00e8re<\/em>, TEOM or special assessments.<\/p>\n

The French tax Code keeps the public and private relationships separate. Article 1402 provides: Les mutations cadastrales cons\u00e9cutives aux mutations de propri\u00e9t\u00e9 sont faites \u00e0 la diligence des propri\u00e9taires int\u00e9ress\u00e9s. Aucune modification \u00e0 la situation juridique d’un immeuble ne peut faire l’objet d’une mutation si l’acte ou la d\u00e9cision judiciaire constatant cette modification n’a pas \u00e9t\u00e9 pr\u00e9alablement publi\u00e9 au fichier immobilier (1).<\/q> A mutation cadastrale<\/em> is the update of the cadastral tax record after a change of ownership; the fichier immobilier<\/em> is the French land-registration file. See Article 1402 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>.<\/p>\n

Article 1403 explains the risk created by a delay: Tant que la mutation cadastrale n’a pas \u00e9t\u00e9 faite, l’ancien propri\u00e9taire continue \u00e0 \u00eatre impos\u00e9 au r\u00f4le, et lui ou ses h\u00e9ritiers naturels peuvent \u00eatre contraints au paiement de la taxe fonci\u00e8re, sauf leur recours contre le nouveau propri\u00e9taire.<\/q> Here, au r\u00f4le<\/em> means on the tax assessment roll. The official wording appears in Article 1403 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>. The words \u201csauf leur recours contre le nouveau propri\u00e9taire\u201d preserve a recourse against the buyer; they do not promise that the tax office will rewrite the deed\u2019s private allocation.<\/p>\n

The distinction is illustrated by the Cour de cassation, Commercial Chamber, decision of 11 July 1995, appeal no. 94-18.996, published in the Bulletin. The case concerned a sale clause requiring the buyer to reimburse \u201cles charges, contributions, taxes et prestations de toute nature, mises ou \u00e0 mettre sur le logement ou le terrain<\/q>\u201d. The Court held that rejecting the seller\u2019s claim by narrowing a clear clause had distorted that clause. The exact decision is available on L\u00e9gifrance, Cour de cassation, no. 94-18.996<\/a>. The point for a British seller is practical: the tax may remain payable by the seller to the State, while a sufficiently clear deed may give the seller a reimbursement claim against the buyer.<\/p>\n

A further illustration appears in the Cour d\u2019appel de Douai decision, RG no. 09\/05607. The official decision records a sale clause for a prorated property tax and states that \u201cle redevable de la taxe fonci\u00e8re \u00e9tant le propri\u00e9taire de l’immeuble au 1er janvier<\/q>\u201d. That decision is available through the Cour de cassation case-law database, RG no. 09\/05607<\/a>. It reinforces the two-ledger approach: the public tax liability is tested on 1 January, while the contract can create a separate reimbursement calculation.<\/p>\n

Another decision, Cour d\u2019appel de Reims, RG no. 18\/02118, applied the same logic where the former owner had paid taxes and sought recovery after a transfer. The court considered the owner on 1 January and the publication of the transfer before that date. Its official record is at Cour de cassation, decision RG no. 18\/02118<\/a>. The decision is useful because it shows why a signed deed, without proof of the necessary land-registration step, may not answer the tax authority\u2019s objection.<\/p>\n

Do not calculate a reimbursement from the sale date unless the deed uses that method. Some deeds use the completion date; others use the date of entry into possession, a calendar-month convention or a specific allocation of TEOM. The exact annual amount can include municipal, inter-municipal and departmental rates, so the calculation should start with the tax notice and the notarial statement, not with an online estimate. If the wording says \u201cthe buyer shall reimburse the seller on first request\u201d, keep the original French clause and a reliable translation together.<\/p>\n

If the clause is clear and the buyer refuses to pay, the dispute is primarily contractual. Article 1344 of the Civil Code defines formal notice to pay and states: Le d\u00e9biteur est mis en demeure de payer soit par une sommation ou un acte portant interpellation suffisante, soit, si le contrat le pr\u00e9voit, par la seule exigibilit\u00e9 de l’obligation.<\/q> The official text is at Article 1344 of the Code civil<\/a>. A formal demand should identify the clause, the tax year, the notice, the amount claimed, the calculation and a reasonable deadline. It should not ask the tax office to decide a private reimbursement issue.<\/p>\n

The position changes if the notice is addressed to you even though the sale completed before 1 January. Article 1404 provides a mechanism where a tax contribution for a year was established in the name of someone other than the legal taxpayer, provided the Article 1402 obligations were respected. It says, in part: Lorsque au titre d’une ann\u00e9e une cotisation de taxe fonci\u00e8re a \u00e9t\u00e9 \u00e9tablie au nom d’une personne autre que le redevable l\u00e9gal, le d\u00e9gr\u00e8vement de cette cotisation est prononc\u00e9 \u00e0 condition que les obligations pr\u00e9vues \u00e0 l’article 1402 aient \u00e9t\u00e9 respect\u00e9es.<\/q> Read the full Article 1404 of the Code g\u00e9n\u00e9ral des imp\u00f4ts<\/a>.<\/p>\n

That condition is why a British owner should ask the notary for the publication evidence rather than rely only on the date on the signature page. Useful documents can include the authentic deed, an attestation of sale, the publication or filing reference, and a written explanation of the date on which the transfer became opposable in the land register. If a notarial office says \u201cthe sale was completed\u201d, ask whether that answer refers to the parties\u2019 signature, the tax file or the land-registration publication. Those are not interchangeable concepts.<\/p>\n

In short, a prorata clause may allow a seller to recover money from the buyer, but it does not automatically remove the seller\u2019s name from the French tax roll. A pre-1 January sale combined with a properly published transfer can support a claim against an incorrect assessment. The date, the record and the clause must be analysed together.<\/p>\n

II. How can a UK owner challenge an incorrect French taxe fonci\u00e8re bill?<\/h2>\n

A. Which evidence, deadline and French complaint should I send?<\/h3>\n

Start by classifying the complaint. A claim that you sold the property after 1 January is usually not a claim that the tax authority assessed the wrong person. A claim that you sold before 1 January and the transfer was properly recorded may challenge the taxpayer identity. A claim that the amount is wrong may concern the property description, assessment base, exemption or local calculation. A claim that the buyer has not reimbursed you under the deed is normally a private contract claim. One letter can mention connected issues, but it should not blur them.<\/p>\n

Build an evidence pack before opening the online form. For a British seller, the minimum pack is:<\/p>\n

    \n
  1. the full avis d\u2019imp\u00f4t<\/em>, meaning the French tax notice, with its tax year, property reference, commune and payment date;<\/li>\n
  2. the authentic deed of sale and any completion statement showing the agreed tax allocation;<\/li>\n
  3. the notary\u2019s attestation, publication reference or other evidence showing when the transfer was filed in the French land register;<\/li>\n
  4. proof of the property\u2019s cadastral references, including the section and parcel numbers where available;<\/li>\n
  5. proof of payment if you have already paid, together with the date and method of payment;<\/li>\n
  6. any letter from the buyer, notary or tax office that explains why the notice remained in your name;<\/li>\n
  7. if challenging the amount, evidence of the specific defect: an incorrect surface, an included parcel, a wrongly retained exemption, or another identifiable assessment error.<\/li>\n<\/ol>\n

    Do not send only a bank statement or a screenshot of the sale listing. The tax office needs to connect the legal transfer to the exact property and tax year. A passport or British council-tax document can prove your identity or address, but it does not prove the French ownership position on 1 January. A deed in English may need a French translation or at least the relevant pages and a clear explanation of the dates.<\/p>\n

    The normal administrative route is a r\u00e9clamation contentieuse<\/em>, which means a formal claim asking the tax administration to reduce or cancel an assessment. Use the secure messaging service in your French espace particulier<\/em> when it is available, select the property-tax category and upload a signed, readable PDF. If online access is unavailable, use the address of the relevant service des imp\u00f4ts des particuliers<\/em> (SIP), the French individual tax office, shown on the notice. Keep proof of submission and the complete documents sent.<\/p>\n

    Article R*197-3 of the French Livre des proc\u00e9dures fiscales<\/em> (Book of Tax Procedures) sets out the formal content. It states that a claim must, on pain of inadmissibility, Mentionner l’imposition contest\u00e9e<\/q> and Contenir l’expos\u00e9 sommaire des moyens et les conclusions de la partie<\/q>. The official text is Article R*197-3 of the Livre des proc\u00e9dures fiscales<\/a>. In practical English, identify the exact assessment, explain briefly why it is wrong and state exactly what you want: full cancellation, a stated reduction, transfer of the assessment or a refund of a stated amount.<\/p>\n

    Attach the notice or a copy of it. The same provision also requires the claim to be signed and accompanied by the relevant tax notice or equivalent proof of the assessment. If using secure messaging, follow the platform\u2019s submission instructions and attach a signed letter so that the formal requirements are clear. Do not assume that an informal message saying \u201cI sold the house\u201d is enough.<\/p>\n

    Check the deadline against the current version of the Code. Article R*196-2 now states: Pour \u00eatre recevables, les r\u00e9clamations relatives aux imp\u00f4ts directs locaux et aux taxes annexes doivent \u00eatre pr\u00e9sent\u00e9es \u00e0 l’administration des imp\u00f4ts au plus tard le 31 d\u00e9cembre de l’ann\u00e9e suivant celle, selon le cas :<\/q> It then refers, among other triggers, to the year in which the assessment roll was put into collection. The current official provision, effective from 30 July 2026, is Article R*196-2 of the Livre des proc\u00e9dures fiscales<\/a>.<\/p>\n

    Do not calculate the deadline solely from the completion date. Read the notice for the date of collection and keep a calendar entry for the applicable 31 December deadline. For example, a notice put into collection during 2026 will generally require a claim by 31 December 2027 under the ordinary local-tax rule. A notice for 2025 will generally point to 31 December 2026. A special event-based rule can apply, so a late discovery or a corrected land-registration event should be described precisely rather than used as an assumption that the deadline has restarted.<\/p>\n

    Your letter can be written in English for a British reader, but the French tax office will process French administrative terminology more efficiently. A clear bilingual subject line can identify the matter: R\u00e9clamation contentieuse \u2013 taxe fonci\u00e8re \u2013 ann\u00e9e [year] \u2013 r\u00e9f\u00e9rence [number]<\/em>. The body should then state the facts in date order, explain whether the sale preceded 1 January, identify the publication evidence and request the precise relief. Keep a French version of the operative request if a translation is needed.<\/p>\n

    A compact structure is:<\/p>\n

      \n
    1. your name, current UK address, French tax number and secure contact details;<\/li>\n
    2. the property address, cadastral references and the tax notice number;<\/li>\n
    3. the sale date, the date shown by the notarial publication evidence and the relevant 1 January date;<\/li>\n
    4. the legal ground: wrong taxpayer, wrong property, wrong amount or a specific relief;<\/li>\n
    5. the sum requested for cancellation, reduction or refund;<\/li>\n
    6. the list of attachments and a request for written confirmation of the decision.<\/li>\n<\/ol>\n

      Use Article 1404 when the problem is an assessment in the name of a person other than the legal taxpayer, but do not state that provision applies merely because the sale happened during the year. Use Article 1507 when the issue is the valuation or property assessment, and identify the factual evidence. If the complaint concerns an exemption or vacancy, cite the relevant conditions and explain how the evidence meets them. A precise claim is easier to answer than a general request to \u201cremove all French taxes after Brexit\u201d.<\/p>\n

      If the property is jointly owned, write in the names of the persons shown on the notice or explain the authority under which one person acts for the others. If the owner has died, an estate representative may need to provide proof of authority. If the property was held through an entity, the taxpayer analysis can differ and the matter may fall outside this personal-owner article. The name on the deed and the name on the tax notice should be compared at the beginning.<\/p>\n

      Finally, separate an incorrect notice from a valid notice followed by a buyer\u2019s default. If you were owner on 1 January and the deed says the buyer must reimburse you, the tax claim may have little prospect even though the contractual claim is strong. If you were no longer the legal owner on 1 January and the transfer was properly recorded, a claim for a d\u00e9gr\u00e8vement<\/em> or correction may be appropriate. Sending both a tax claim and a contractual demand can be sensible, but each should identify its own addressee and remedy.<\/p>\n

      B. Can I request sursis de paiement and take the dispute to court?<\/h3>\n

      Filing a complaint does not, by itself, mean that the disputed tax can be ignored. If the payment date is approaching and you genuinely dispute the legal basis or amount, ask expressly for a sursis de paiement<\/em>, meaning a deferral of payment of the disputed part. The request must be linked to the formal complaint; it should not be hidden in a final sentence or left to inference.<\/p>\n

      Article L277 of the Livre des proc\u00e9dures fiscales states: Le contribuable qui conteste le bien-fond\u00e9 ou le montant des impositions mises \u00e0 sa charge est autoris\u00e9, s’il en a express\u00e9ment formul\u00e9 la demande dans sa r\u00e9clamation et pr\u00e9cis\u00e9 le montant ou les bases du d\u00e9gr\u00e8vement auquel il estime avoir droit, \u00e0 diff\u00e9rer le paiement de la partie contest\u00e9e de ces impositions et des p\u00e9nalit\u00e9s y aff\u00e9rentes.<\/q> The complete official text is Article L277 of the Livre des proc\u00e9dures fiscales<\/a>.<\/p>\n

      The rule has three practical requirements. First, make the request expressly in the complaint. Secondly, identify the amount or tax base of the reduction requested. Thirdly, distinguish the disputed part from any amount that is accepted. Article L277 also provides that the enforceability of the claim and the limitation period for collection are suspended until a final decision on the complaint by the administration or competent court, subject to the statutory safeguards. The administration can require guarantees where the contested amount exceeds the applicable threshold, and insufficient guarantees can lead to protective collection measures.<\/p>\n

      A safe letter therefore says what is being disputed and what is not. If the full assessment is challenged because you were not the legal taxpayer, state the full amount and request suspension of that amount. If only the valuation of one parcel is challenged, pay or arrange the undisputed part and identify the exact balance. Keep proof of the complaint, the request for deferral and any response. A payment demand from the comptable public<\/em>, the public revenue officer, should not be ignored while the file is being assembled.<\/p>\n

      If you have already paid, a successful complaint can lead to a refund or a credit, depending on the administration\u2019s decision and the account position. A reimbursement clause with the buyer is separate: payment of the tax does not prove that the buyer owes the same amount, and a tax refund does not necessarily settle a contractual dispute over TEOM or another line. Reconcile the final amount against the notice, the deed and any payment received from the buyer.<\/p>\n

      If the tax office rejects the claim, read the reasons and the date of notification. A request for review, further evidence or a corrected complaint may be useful where the decision misunderstood the deed or publication date. Where the dispute concerns the tax assessment itself, the route is generally the tribunal administratif<\/em>, the administrative court, rather than a civil court. The official Cour d\u2019appel de Douai decision, RG no. 25\/02502, records that for property tax, the ordinary courts do not decide questions concerning the tax procedure, merits or penalties, which fall within the administrative courts\u2019 jurisdiction. The case record is available at Cour de cassation, decision RG no. 25\/02502<\/a>.<\/p>\n

      This jurisdiction point matters for a British owner because a contract dispute and a tax dispute can travel on different tracks. A claim against the buyer for reimbursement under the deed is a civil or contractual matter. A claim asking the French State to cancel an assessment is an administrative-tax matter. A notary\u2019s professional responsibility may raise a third question. Identify the decision being challenged before choosing a court.<\/p>\n

      Do not use the existence of a prorata clause as a substitute for an administrative complaint. If the tax office is correctly charging you for the year in which you owned the property on 1 January, the clause may help you recover the agreed share from the buyer, but it will not make the tax office refund a valid assessment. If the office is charging you for a year after a properly published pre-1 January sale, the clause may be irrelevant to the public correction: the priority is the land-record evidence and the formal tax claim.<\/p>\n

      Likewise, do not treat a letter from the notary as a tax-office decision. The notary can confirm the deed, payment allocation and publication process, but the tax administration decides the assessment. Ask for the specific publication date or reference, then send that document to the SIP<\/em>. If the notary says the file is pending, ask whether the tax notice should be challenged now rather than waiting for an internal correction that may not protect a statutory deadline.<\/p>\n

      For a non-resident, practical safeguards are important:<\/p>\n