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FranceFrance · US corridor

US expat taxes in France —
your assurance-vie is the standard advice and a standard problem.

A US citizen living in France generally stays inside the US federal filing system on worldwide income. French tax is high enough that the Foreign Tax Credit usually removes the US tax on salary — so the hard part is not the tax. It is that assurance-vie and the PEA are the default French way to save, and both are typically PFIC territory.

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What actually applies

The layers a French return runs through.

Not everyone needs every form. These are the layers that come up most for Americans in France, and what makes each one bite here.
US filing layers that commonly apply to a US person living in France
FormWhat it isWhat makes it bite in France
Form 1040The US federal return, on worldwide income.Filed regardless of French residence. Euro converts at the IRS yearly-average rate; the French and US tax years both run calendar-year, so the periods align.
Form 1116Foreign Tax Credit for foreign income tax paid.Impôt sur le revenu on salary usually exceeds US tax on the same income. Since 2019 IRS guidance, CSG/CRDS feed the same credit — a real addition to the credit base, not a separate question.
FinCEN 114 (FBAR)Report of non-US financial accounts once the combined peak exceeds $10,000.Compte courant, livret, PEA, brokerage accounts, and commonly the assurance-vie contract itself. French banking spreads you across accounts, and they aggregate.
Form 8938FATCA reporting of specified foreign financial assets, filed with the return.Higher thresholds than the FBAR — from $200,000 year-end for a single filer abroad — but a broader class of assets, which reaches insurance-wrapped contracts like assurance-vie.
Form 8621One per PFIC per year, subject to the form's own triggers.PEA and assurance-vie fund allocations. A diversified PEA is several forms a year, indefinitely — this is where a French return stops being routine.
Form 3520 / 3520-AForeign trust reporting, when the arrangement is classified as one.Whether a specific assurance-vie contract triggers this depends on its structure and insurer — a genuine classification question, not a routine filing.
Form 8833Disclosure of a treaty-based return position that overrides the default treatment.Not needed for the ordinary Form 1116 credit, including the CSG/CRDS credit. A pension-article override is the usual reason it comes up.
Streamlined (Form 14653)The catch-up route for non-willful taxpayers living abroad.A common path for the long-settled American population across Paris, Lyon and the south of France.

A form listed here does not mean it applies to you. Which of these your return needs depends on your accounts, holdings and income.

Salary and accounts

The easy half of a French return.

French tax on employment income does most of the work. It is worth knowing which parts are genuinely simple before getting to the parts that are not.

French salary, CSG/CRDS and the Foreign Tax Credit

Impôt sur le revenu withheld at source (prélèvement à la source), plus CSG and CRDS social charges, generally exceeds the US tax on the same income. Since 2019 IRS guidance treats CSG/CRDS as creditable, both flow into the same Form 1116 credit.

Your avis d'impôt is the cleanest evidence of French tax actually assessed, year by year — exactly what the credit needs.

How the Foreign Tax Credit works

French accounts: reporting, not tax

A compte courant, a livret, a PEA, a brokerage account — each is a non-US financial account. The FBAR adds their peaks together, so accounts that each look small can cross $10,000 between them.

An assurance-vie contract is not a French tax filing shortcut here either — it typically counts toward the same reporting, on top of its own possible Form 3520 question.

FBAR filing guide, in detail

If you have an assurance-vie or PEA

A savings contract full of unités de compte?

Assurance-vie and the PEA are the two products almost every French saver holds, and their fund allocations are almost always non-US SICAV or FCP shares — French, Irish or Luxembourg domiciled, and generally PFICs. Generally one Form 8621 per fund per year, and a diversified contract can hold several.

The euro-fund (fonds en euros) portion of an assurance-vie and direct shares in LVMH or TotalEnergies held outside a wrapper are not PFICs.

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Check your PEA or assurance-vie for PFICs.

Pick where you hold it — a French bank, Boursorama, Fortuneo, IBKR — and what you hold, or paste the ISINs from your relevé.

1 · Where do you live?

Where you live changes the products you are likely to hold and the guidance you get next. It does not change how the PFIC rules classify a holding — those turn on the fund, not your address.

2 · Where do you hold it?
3 · What do you hold?

Result

Tell us what you hold

Pick the closest match on the left, or paste your ISINs below and we'll flag each one.

More for US taxpayers in France: The France treaty desk.

Educational estimate, not tax advice. Domicile is the fund's legal home, not the broker or exchange you used. Broker and provider policies change — confirm current terms with your provider before acting.

Behind on filings?

The penalty-free route back, from France.

France has a large, long-settled American population and a steady stream of people who find out years in. The programme exists for exactly that.

A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs, with the offshore penalty at 0%. Two gates: non-willful conduct, and the non-residency test — at least 330 days abroad in at least one of the last three years.

On salary, the tax across those years is often little or nothing after the credit for French tax and social charges. The volume is in the information returns — a five-year-old PEA or assurance-vie produces one Form 8621 per fund per year across the whole window.

You certify non-willfulness on Form 14653, under penalty of perjury. Atamatax prepares the return side and does not generate Form 14653, assemble the mailing, or transmit anything to the IRS or FinCEN.

The treaty, in short

The 1994 convention, and CSG/CRDS creditability.

France

US–France Convention 1994

The convention allocates taxing rights and provides relief from double taxation — for a US citizen, almost always as a credit on Form 1116. The saving clause preserves US taxation of citizens subject to the exceptions listed in Article 1.

  • Article 10 — dividends. Article 11 — interest. Article 13 — capital gains.
  • Article 18 — pensions and similar remuneration.
  • CSG/CRDS: creditable as foreign income tax since 2019 IRS guidance, not a pre-treaty-era assumption.
  • Form 8833 is for a position that overrides the default treatment, not for the ordinary credit.
  • Nothing in the convention displaces the PFIC rules, which are US domestic law.
The France treaty desk, article by article →

The France treaty desk does the article-level work, including the full CSG/CRDS credit position. This page exists for the broader question of what living in France does to a US return.

Paris has its own guide too, for city-level detail on finance, tech and academic employers and the dual-national community.

Related

Other country desks

The layers a US return runs through don't change by country — what changes is which local accounts, funds and pensions actually trigger them. Here's how France compares.

US taxes in France — the questions we get

Do Americans living in France still have to file US taxes?#
Generally yes. US citizens and green-card holders file a US federal return on worldwide income wherever they live, and French tax residence does not end that. French income tax is usually high enough that the Foreign Tax Credit on Form 1116 removes most or all of the US tax on salary, but the return and any reporting forms are still required.
Is my assurance-vie a problem for US taxes?#
Often, yes. Assurance-vie is France's most popular long-term savings product, but the underlying unit-linked funds are typically non-US pooled vehicles that meet the PFIC tests, and the contract's own structure can raise separate US classification and reporting questions beyond the fund-level PFIC issue. A euro-fund-only contract with no unit-linked allocation is a narrower question than one with a fund mix.
Is my PEA a PFIC?#
The plan d'épargne en actions wrapper itself isn't a PFIC — it's a French tax-favoured account. What sits inside one usually is: PEA-eligible funds are commonly French, Irish or Luxembourg SICAV or FCP shares, which are non-US pooled vehicles and generally meet the PFIC tests. The account's French tax deferral does not change the US analysis.
Can I credit French CSG and CRDS against my US tax?#
Generally yes, since 2019 IRS guidance treats CSG and CRDS as creditable foreign income tax alongside impôt sur le revenu, feeding the same Form 1116 credit rather than sitting outside it. It was a genuinely unsettled question before that guidance, so a return prepared on older assumptions is worth revisiting.
Do French bank and brokerage accounts count for the FBAR?#
Generally yes. A compte courant, livret or brokerage account at a French institution is a non-US financial account, and the combined peak value across all of them counts toward the $10,000 FinCEN Form 114 threshold. A PEA and an assurance-vie contract commonly count too.
Do I need Form 8938 for my French accounts?#
Possibly, and it is a separate test from the FBAR. For a single filer living abroad Form 8938 starts at $200,000 in specified foreign financial assets at year end or $300,000 at any point; married filing jointly, $400,000 and $600,000. It covers a broader class of assets than the FBAR, including some insurance-wrapped contracts, so the two thresholds do not move together.
When does an assurance-vie need Form 3520?#
It depends on how the specific contract and insurer arrangement is classified for US purposes — not every assurance-vie is treated as a foreign trust, but the question needs asking rather than assuming either answer. Getting this wrong in either direction (over-filing or under-filing) has real consequences, so it is worth a dedicated review.
Can Americans in France use Streamlined procedures?#
Living in France neither qualifies nor disqualifies you. The Streamlined Foreign Offshore Procedures require non-willful conduct and the non-residency test — at least 330 days abroad in at least one of the last three years. A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs with a 0% offshore penalty, certifying non-willfulness on Form 14653.
Does the US–France totalization agreement change where I pay social security?#
It can. The agreement assigns social-security coverage to one country rather than both, documented by a certificate of coverage, for a worker moved between the US and France. It governs contributions; the income tax treaty and the CSG/CRDS creditability position separately govern how income and social charges are taxed.

Authorities cited

  • IRC §1297IRC §1297 — Definition of a passive foreign investment company
  • IRS Form 8621About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
  • IRC §1291IRC §1291 — Interest on tax deferral (excess-distribution regime)
  • IRC §1296IRC §1296 — Mark-to-market election for marketable PFIC stock
  • IRC §6048IRC §6048 — Information reporting for foreign trusts (Forms 3520 / 3520-A)
  • IRS Form 3520About Form 3520 — Annual Return To Report Transactions With Foreign Trusts
  • FinCEN Form 114 (FBAR)Report of Foreign Bank and Financial Accounts (FBAR)
  • 31 CFR §1010.35031 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
  • IRS Form 8938About Form 8938 — Statement of Specified Foreign Financial Assets
  • IRC §6038DIRC §6038D — Information reporting of specified foreign financial assets (Form 8938)
  • IRS Form 1116About Form 1116 — Foreign Tax Credit (Individual, Estate, or Trust)
  • IRC §904IRC §904 — Limitation on the foreign tax credit
  • US–France Income Tax TreatyConvention between the United States and France (signed 1994), as amended by the 2004 and 2009 Protocols
  • U.S.–France Totalization AgreementU.S.–France Social Security (Totalization) Agreement
  • IRS Streamlined Foreign Offshore ProceduresU.S. Taxpayers Residing Outside the United States — Streamlined Foreign Offshore Procedures

Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.

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