US Expat Taxes in France

Check US filing obligations before estimating tax

US citizens and resident aliens generally remain subject to US tax on worldwide income while abroad. Check filing status, age, income and special filing requirements for the relevant year; the standard deduction alone is not a universal filing threshold. Publication 54 also identifies a filing requirement when net self-employment earnings reach $400.

A return may be required even when an exclusion or credit reduces the tax. Foreign-account and other information returns have their own conditions and thresholds. Gather income and account records rather than assuming every listed form applies, or that French tax means no US balance is due.

Sources, read September 24, 2026: https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad; https://www.irs.gov/publications/p54.

How French Income Tax Works in 2026

For 2025 income declared in 2026, the French progressive bands per household part are 0% up to €11,600; 11% from €11,601 to €29,579; 30% from €29,580 to €84,577; 41% from €84,578 to €181,917; and 45% above €181,917. These are marginal bands, not a single rate on all income. The household calculation and applicable adjustments determine the final assessment.

High-income households need a separate review of CEHR and CDHR. The CDHR was continued for 2026. Its calculation uses adjusted reference income and adjusted taxes, with household allowances; simply applying 20% to total income does not calculate the amount due. The published reference-income thresholds are above €250,000 for single, widowed, separated or divorced taxpayers and €500,000 for jointly assessed couples.

For covered capital income from January 1, 2026, the standard PFU is 31.4%: 12.8% income tax and 18.6% social levies. A progressive-scale election is available. Check the product and payment year: DGFiP lists exceptions retaining 17.2% social levies, including qualifying assurance-vie and capitalisation products. Some investment income received in 2025 without social levies at collection is assessed at 18.6% on the 2026 assessment.

For the US foreign tax credit, identify each levy and the legal tax actually paid or accrued. Withholding alone does not establish the allowable credit, and refunds or treaty reductions can change it.

Sources for the corrected passages, read September 24, 2026: https://entreprendre.service-public.gouv.fr/actualites/A18796; https://www.impots.gouv.fr/particulier/les-revenus-mobiliers; https://www.irs.gov/individuals/international-taxpayers/foreign-taxes-that-qualify-for-the-foreign-tax-credit.

Sources, read September 24, 2026: https://www.service-public.gouv.fr/particuliers/vosdroits/F1419; https://www.service-public.gouv.fr/particuliers/actualites/A18878.

France and US returns: compare the same income and year

Use a separate calculation for each country, then reconcile the results for the same income year.

• Tax year: France’s spring 2026 declaration reports 2025 income. Do not compare that assessment with US 2026 thresholds as though they cover the same period.
• Tax base: reconcile the income included on each return before comparing rates or claiming relief. Keep the French assessment and the US income-category calculations together.
• Credits: French tax withheld is not automatically the amount creditable in the United States. Review the legal liability, refunds, exclusions and treaty relief.
• Currency: taxes claimed on the paid basis generally use the payment-date exchange rate; accrued taxes generally use the relevant year’s average, with exceptions. This is not a free choice between the two rates.

Use the detailed income, treaty and reporting sections below to identify the records needed for your circumstances.

Sources, read September 24, 2026: https://www.impots.gouv.fr/les-modalites-de-la-declaration-de-revenus-en-2026; https://www.irs.gov/instructions/i1116.

CSG and CRDS: review credit eligibility

The IRS says it will not reject CSG and CRDS foreign tax credits on the ground that those levies fall under the US-France Social Security Agreement. This removes that specific objection; it does not make every French levy or every amount withheld automatically creditable.

Keep the assessment, payment evidence and levy breakdown. Apply the ordinary credit requirements to the taxpayer, income and year, including any treaty reduction or refund.

The IRS generally allows a ten-year refund-claim period for additional creditable foreign taxes, starting the day after the unextended regular return due date for the year the taxes were paid or accrued. Its instructions for these claims call for Form 1040-X with Form 1116 and the notation “French CSG/CRDS Taxes” in red at the top.

Sources for the corrected passages, read September 24, 2026: https://www.irs.gov/individuals/international-taxpayers/foreign-tax-credit; https://www.irs.gov/individuals/international-taxpayers/foreign-taxes-that-qualify-for-the-foreign-tax-credit.

Determine French residence for each person

DGFiP identifies domestic residence criteria involving the home, the principal stay when there is no home, non-accessory professional activity, or the centre of economic interests. Assess each person separately. If both countries treat a person as resident, consult the applicable treaty residence rules.

A French tax resident is generally taxed on French and foreign income, subject to treaty provisions. Moving during the year does not by itself make a US citizen a part-year US taxpayer. Record arrival and departure dates, homes, work locations and family circumstances before determining obligations.

Sources, read September 24, 2026: https://www.impots.gouv.fr/resident-de-france; https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad.

French returns, foreign-income annexes and supporting records

Check prefilled income and withholding against your records. An annual French return reconciles the prior year; withholding does not replace that review.

• Form 2042 is the main return. Where required, use Form 2047 to detail foreign income and carry amounts to the appropriate return lines; particular exempt salary and pension cases follow different instructions.
• The credit mechanism determines the reporting route. DGFiP distinguishes foreign-tax credits reported on Form 2042-C from French-tax-equivalent relief using income amounts on Form 2042, including line 8TK. Do not put every treaty credit in one box.
• Forms 3916/3916-bis: review foreign accounts and the relevant annex requirements. DGFiP describes a limited exception when an account serves only online purchases or receipts from goods sales, is linked to a French account, and annual receipts do not exceed €10,000; the conditions are cumulative. Do not assume every PayPal balance must be declared or that every digital-asset account has the same penalty rules as a bank account.

Keep the filed returns, avis d’imposition, payment records and any refund notices together. For Form 1116, apply the paid-or-accrued currency rules and their exceptions to eligible taxes; neither the assessment nor its total alone establishes the US credit.

Sources, read September 24, 2026: https://www.impots.gouv.fr/les-modalites-de-la-declaration-de-revenus-en-2026; https://www.impots.gouv.fr/particulier/questions/comment-seront-imposes-mes-revenus-percus-de-letranger; https://www.impots.gouv.fr/particulier/questions/dois-je-declarer-mon-compte-paypal-ou-un-compte-bancaire-ouvert-letranger-et; https://www.irs.gov/instructions/i1116.

US-France treaty: identify the applicable relief

Read the 1994 convention together with its protocols. The 2009 protocol renumbered Article 24: paragraph 1 addresses French relief and paragraph 2 US relief.

Article 24 does not provide one credit formula for every payment. Depending on the provision and eligibility, French relief can equal the attributable French tax or qualifying US tax, subject to limits. The special rule for US citizens resident in France has income, payer and compliance conditions.

Source documents, read September 24, 2026: https://www.irs.gov/pub/irs-trty/france.pdf; https://home.treasury.gov/system/files/131/Treaty-France-Pr2-TE-1-13-2009.pdf.

Treaty re-sourcing and the limits of US credits

For a US citizen resident in France, Article 24(2)(b) coordinates the US credit with French relief. Re-sourcing applies only as needed under that provision, including its French gross-income inclusion condition; it does not make every French tax on US income creditable.

Calculate relief for each income item before completing the returns. Keep the payer details, income classification and both countries’ tax calculations together.

How it appears on Form 1116

Apply the Form 1116 category rules to the specific treaty position. The usual separate-limit rule has an exception for relief provisions applying solely to US citizens resident in the treaty country. Form 8833 may be required; review the disclosure rules rather than treating it as mandatory for every case.

No credit against the NIIT

On August 31, 2026, the Federal Circuit reversed the lower-court judgment in Christensen and held that the US-France Convention’s foreign tax credits could not offset the net investment income tax. Do not assume a Form 1116 credit eliminates NIIT, or calculate the combined tax by simply adding a French headline rate to 3.8%.

Sources for the corrected passages, read September 24, 2026: https://www.cafc.uscourts.gov/opinions-orders/24-1284.OPINION.8-31-2026_2747783.pdf; https://www.irs.gov/instructions/i1116.

Treaty sources, read September 24, 2026: https://www.irs.gov/pub/irs-trty/france.pdf; https://home.treasury.gov/system/files/131/Treaty-France-Pr2-TE-1-13-2009.pdf.

Compare FEIE and foreign tax credits using your records

For 2026, the maximum foreign earned income exclusion is $132,900. Eligibility requires foreign earned income, a foreign tax home and a qualifying residence or physical-presence test. The exclusion does not reduce self-employment tax.

Compare eligible income, taxes, timing and prior elections before choosing treatment. You cannot claim a foreign tax credit for taxes attributable to excluded income. If an exclusion choice is revoked and you want to choose it again within five years, IRS approval is required. Neither method promises a zero balance or refundable child credit.

Sources, read September 24, 2026: https://www.irs.gov/pub/irs-drop/rp-25-32.pdf; https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion; https://www.irs.gov/individuals/international-taxpayers/foreign-tax-credit; https://www.irs.gov/publications/p54.

Confirm social-security coverage before claiming an exemption

SSA assigns self-employed workers who work only in France to French coverage. A worker normally active in the United States who transfers the business to France for two years or less remains under US coverage. Work in both countries is assigned according to the principal activity.

Document work locations, transfer dates and the relevant certificate of coverage. Do not assume French residence alone eliminates US self-employment tax. Employees require the applicable employee coverage review. Keep contribution coverage separate from the income-tax treatment of benefits.

Sources, read September 24, 2026: https://www.ssa.gov/international/Agreement_Pamphlets/france.html.

French pensions: payments, contributions and reporting

Identify the plan and payment before applying a pension rule. Keep the plan documents, contribution history, distribution statements and residence history. Review contributions, accumulated income, distributions and information reporting separately.

Article 18 uses source-country taxation for covered cross-border pension payments. The 2009 explanation also confirms French-only taxation of French social security payments to a US citizen resident in France. Do not extend that result to every retirement product.

A French deduction does not by itself establish the US treatment of a contribution. The IRS directs taxpayers to the applicable treaty for any cross-border contribution benefits. Review the particular PER or occupational plan instead of assuming an automatic deduction, current tax charge, PFIC classification or foreign-trust filing.

Sources, read September 24, 2026: https://www.irs.gov/businesses/the-taxation-of-foreign-pension-and-annuity-distributions; https://home.treasury.gov/system/files/131/Treaty-France-Pr2-TE-1-13-2009.pdf.

Assurance-vie: gather the contract before classification

For an assurance-vie review, bring the complete contract, benefit provisions, premium history, withdrawal records and underlying holdings. Ask which US classification and reporting rules apply to that contract.

Do not treat “assurance-vie” as a determination that every contract is a foreign trust, a PFIC interest or US-qualified life insurance. Separate the contract analysis from any analysis of underlying investments. Avoid a surrender or investment decision based only on the account’s French tax label.

Review references, read September 24, 2026: https://www.irs.gov/instructions/i8621; https://www.irs.gov/businesses/the-taxation-of-foreign-pension-and-annuity-distributions

Review investments for PFIC reporting

PFIC status is determined for a foreign corporation under income and asset tests: at least 75% passive gross income, or at least 50% passive assets under the applicable measurement rules. A direct shareholding is not automatically outside these rules.

Form 8621 obligations depend on ownership, distributions, dispositions, elections and annual-reporting requirements, with exceptions. The default section 1291 rules, QEF treatment and mark-to-market treatment differ; do not assume all income is taxed in the same way.

Before buying, selling or making an election, gather the holding history and issuer information needed to review classification and available treatment. This guide does not recommend a fund, brokerage or liquidation strategy.

Source, read September 24, 2026: https://www.irs.gov/instructions/i8621

Records to collect for French savings products

Prepare a record for each assurance-vie, PEA, Livret A and PER: the provider and legal account holder, opening date, contributions, withdrawals, annual statements, income, taxes withheld and underlying holdings. Include the contract or plan rules where applicable.

Ask the preparer to separate account reporting, current income, distributions, treaty treatment and any investment-level reporting. Do not assume that holding only individual shares makes an account safe, or that a French deduction establishes the US deduction. Confirm consequences before changing an investment or surrendering a contract.

Review references, read September 24, 2026: https://www.irs.gov/instructions/i8621; https://www.irs.gov/businesses/the-taxation-of-foreign-pension-and-annuity-distributions

Property sales and the separate IFI review

For a home sale, collect purchase and sale records, improvements, occupancy dates, prior exclusions and rental or business use. Review US gain and any home-sale exclusion separately from the French calculation. Publication 523 describes the ownership, residence and look-back tests, disqualifications, and possible partial exclusion; do not assume a sale always creates US tax or automatically qualifies for the maximum exclusion.

IFI concerns net taxable real-estate wealth exceeding €1.3 million at January 1, 2026. Review household membership, residence, asset scope, exemptions and eligible debts. The 2026 instructions describe conditional temporary relief for some people transferring tax residence to France, limiting scope to French property for up to five years. It is not an automatic exemption for every arrival.

Do not treat a property-value tax as a foreign income-tax credit. Review any tax on rental income or a sale separately, using the legal liability and applicable credit limits. This guide does not recommend changing ownership or debt to obtain a tax result.

Sources, read September 24, 2026: https://www.irs.gov/publications/p523; https://www.impots.gouv.fr/sites/default/files/formulaires/2042-ifi/2026/2042-ifi_5480.pdf; https://www.irs.gov/individuals/international-taxpayers/foreign-taxes-that-qualify-for-the-foreign-tax-credit.

Prepare a two-country business review

Before choosing or changing a French business structure, assemble ownership documents, formation dates, liability provisions, prior classification elections and financial records. Confirm the US classification separately from the French tax regime.

Check the applicable social-security coverage and certificate using the work and transfer history. Confirm income-tax and information-return requirements separately; a company name or a French tax payment does not resolve all US obligations.

Sources, read September 24, 2026: https://www.irs.gov/pub/irs-pdf/f8832.pdf; https://www.irs.gov/instructions/i5471; https://www.ssa.gov/international/Agreement_Pamphlets/france.html.

Micro-entrepreneur records and entity elections

For 2026–2028, Service Public lists a €203,100 threshold for sales and specified accommodation activities and €83,600 for services and liberal professions. Mixed activities and a start during the year require additional checks; the thresholds are prorated for a midyear start. Confirm the exact activity category rather than applying the higher figure to every furnished rental.

For US classification, a foreign eligible entity’s default depends on the number of owners and limited liability. An eligible single-owner entity can elect disregarded treatment. An election generally cannot take effect more than 75 days before filing or more than 12 months afterward; late-election relief has conditions. This is not a universal deadline measured from formation.

CFC status and Form 5471 obligations require the relevant ownership, attribution and filer-category analysis. Missing a 75-day window does not itself prove CFC status. Confirm the applicable year’s inclusion and election rules before assuming a French headline corporate rate removes US tax.

Sources, read September 24, 2026: https://entreprendre.service-public.gouv.fr/actualites/A18813; https://www.irs.gov/pub/irs-pdf/f8832.pdf; https://www.irs.gov/instructions/i5471.

Behind on Filings, Key Deadlines, and How Zenith Helps

Start by reviewing your filing history, residence, prior IRS contact and the reason for each omission. The foreign streamlined procedures require eligibility and a non-willfulness certification. For US citizens and green-card holders, the non-residency test requires no US abode and at least 330 full days outside the United States in at least one of the relevant three years; both spouses must qualify on a joint submission.

An eligible submission covers the three specified overdue return years and six specified overdue FBAR years, includes required information returns, and pays tax and interest. Specified penalty relief depends on eligibility and following every instruction; it is not a promise of no tax, no audit or a refund. Previous penalty assessments are not abated.

Prior delinquent filings do not automatically exclude an otherwise eligible taxpayer. A civil examination or criminal investigation does; other IRS contact needs review.

Sources, read September 24, 2026: https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures; https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states.

Your two-country calendar — 2025 income, filing in 2026

• US: April 15 is the regular calendar-year deadline. Eligible citizens or residents abroad receive a two-month filing and federal income-tax payment extension, but interest runs from April 15. Attach the required qualification statement. Request the additional filing extension by the applicable deadline for October 15; it does not add payment time.
• FBAR: April 15, with an automatic extension to October 15 without a separate request. Check whether specific relief applies.
• France: online deadlines were May 21 for departments 01–19 and nonresidents, May 28 for 20–54, and June 4 for 55–974/976. The paper deadline was May 19. These are 2026 dates, not an announcement of the 2027 calendar.

Sources, read September 24, 2026: https://www.irs.gov/publications/p54; https://www.fincen.gov/news/news-releases/new-due-date-fbars-0; https://www.impots.gouv.fr/les-modalites-de-la-declaration-de-revenus-en-2026.

Discuss your US filing needs while living in France in a free 15-minute introductory consultation. Bring your filing history and questions about income, pensions, investments or property. Confirm which work can be included, the fees and the responsibilities before starting a paid engagement.