If you work in France, your payslip already carries more tax than the IRS would ask for on the same salary, once you count CSG and CRDS. So the US return is rarely about paying twice. It’s about claiming the credit properly, reporting every French account, and not getting caught by the savings products your bank conseiller recommends to everyone.
We’ll take it in the order people usually ask: what’s due when, how the French and US taxes fit together, and then the accounts.
Do Americans in France really have to file with the IRS every year?
Yes. The US taxes citizens and green-card holders on worldwide income wherever they live, and the US–France treaty doesn’t change that. Its saving clause (Article 29(2)) lets the US tax you as if the treaty didn’t exist, apart from a short list of exceptions we’ll come to. So you file a 1040 as well as your French déclaration de revenus (Form 2042), even though French tax is already taken from your pay each month through the prélèvement à la source.
That includes dual citizens, people who moved for a job in Paris twenty years ago, and accidental Americans who were born in the US and have never lived there. A French spouse with no US income normally has no US filing obligation of their own.
When are the French and US returns due for 2025?
France and the US both tax the calendar year, so your 2025 figures line up. The deadlines don’t:
- 1
15 April 2026 · US tax payment due
Filing can wait; paying late costs interest from this date.
- 2
19 May 2026 · French paper return
For the few who still file on paper.
- 3
21 May, 28 May or 4 June 2026 · French online return
21 May for départements 01–19, 28 May for 20–54, 4 June for 55 onward (Paris is 75, so 4 June). It depends on where you lived on 1 January 2026.
- 4
15 June 2026 · US return, automatic for Americans abroad
Attach a statement that you lived and worked outside the US on 15 April.
- 5
15 October 2026 · US return with Form 4868, and the FBAR
File Form 4868 by 15 June. The FBAR extends to 15 October automatically.
Your avis d’imposition, the notice that fixes your final French tax for 2025, usually lands in the summer. That’s after the June deadline, so for anyone with more than a plain salary we tend to extend to October and file on the final French figure rather than on what was withheld. Otherwise you risk amending later.
For currency, use the IRS yearly average rate for 2025, €0.886 per $1, for salary, interest and tax withheld through the year. Sales of shares, property or a fund use the rate on the day of the sale.
Foreign tax credit or the exclusion for a French salary?
Our default for almost everyone employed in France is the foreign tax credit (Form 1116), not the foreign earned income exclusion. The exclusion shelters up to $130,000 of 2025 earnings, which covers most French salaries, but it throws away the extra French tax you’ve paid.
French income tax on 2025 income starts at 11% above €11,600 per part, then 30% above €29,579, 41% above €84,577 and 45% above €181,917. On top of that come CSG and CRDS, 9.7% on almost all of your gross pay. For years the IRS refused to credit those two, arguing the totalization agreement covered them. It lost in Eshel at the D.C. Circuit in 2016 and in August 2019 said it would stop challenging the credit. They count now, and they’re usually what pushes your creditable French tax well past the US bill.
The unused credit carries forward ten years. The credit route also keeps you able to fund an IRA or Roth IRA, which excluded income can’t, and keeps the refundable part of the child tax credit available if your children have Social Security numbers.
The exclusion still makes sense when your French tax is unusually low, for instance in a first year where much of your pay is an impatriation bonus France doesn’t tax. If your employer pays for housing in Paris, the housing exclusion can apply too: the 2025 cap for Paris under IRS Notice 2025-16 is $65,700, less the $20,800 base.
Say you’re single, in Lyon, on €75,000 gross
That’s about $84,650 of wages at the 2025 rate. After social contributions and the 10% allowance for professional expenses, your French taxable income is roughly €53,000, and French income tax on one part comes to about €9,000 (around $10,200). CSG and CRDS on your pay add about €7,150 ($8,070).
On the US side, $84,650 less the $15,750 standard deduction leaves $68,900 taxable, and the 2025 tax on that is about $10,070. Your creditable French tax is about $18,200, so US tax is zero and roughly $8,100 of unused credit carries forward. The exclusion would also get you to zero this year, with nothing to carry.
These are rounded figures. Your actual French tax depends on your contributions and household.
How does the treaty stop France taxing my US income?
This is the unusual part of the French treaty, and it works in your favour. Under Article 24(2)(b), if you’re a US citizen living in France, France includes your US dividends, US interest, gains on US shares, and US pensions earned from work in the US in your French income, then gives you a credit equal to the French tax on them. The income counts for your French rate, but France collects no income tax on it. The US taxes it once. France only allows this if you can show you’re compliant with the IRS, which is one more reason to keep your 1040s current.
Your US brokerage account at Schwab or Fidelity is therefore fine from France’s side, provided the broker lets you keep it. The social charges France levies on investment income are a separate matter for your French adviser. What doesn’t work is the reverse: French investment wrappers get no special treatment from the IRS.
What happens to my Livret A, PEA and French funds on a US return?
This is where most Americans in France go wrong, usually because a bank conseiller set things up the way they would for any French client.
| French account | In France | On your US return |
|---|---|---|
| Livret A, LDDS, LEP | Interest tax-free (Livret A capped at €22,950) | Interest fully taxable, no French tax to credit |
| PEA | Gains free of income tax after 5 years; social charges still due | No treaty protection; taxed like a normal account; funds inside are usually PFICs |
| French funds (OPCVM, SICAV, FCP, UCITS ETFs) | Taxed on sale or distribution | Usually PFICs: Form 8621 each, punitive tax without an election |
| Épargne salariale (PEE, PERCO / PER collectif) | Employer top-up (abondement) and gains largely sheltered | Abondement is taxable wages; the FCPE funds are usually PFICs |
| Assurance-vie | €4,600 / €9,200 allowance on gains after 8 years | Unsettled; see below |
A PFIC (passive foreign investment company) is how the US classifies almost any non-US pooled fund. Without an election, when you sell or take a large distribution the gain is spread back over the years you held the fund, taxed at the top US rate for each year, and charged interest. The usual fix for listed ETFs is a mark-to-market election, which taxes the rise in value every year as ordinary income. That beats the default. It still hurts inside a PEA, because France isn’t taxing anything that year, so there’s nothing to credit.
Take Emma, an American in Nantes with a Livret A and a PEA
Emma’s Livret A paid about €400 of interest in 2025 (about $450). Her PEA holds a French-domiciled MSCI World ETF her bank suggested, worth €40,000 at year-end and up €4,000 over the year (about $4,500). She withdrew nothing.
France taxes neither. The US taxes both: the interest as ordinary income, and the ETF’s gain as ordinary income under the mark-to-market election. At a 22% bracket that’s about $1,090 of US tax with nothing French to set against it. The spare credit from her salary doesn’t help, because it sits in the general category and this is passive income. She also files Form 8621 for the ETF and an FBAR, since her accounts together passed $10,000.
For new money the fix is simple: hold French shares directly in the PEA if you want one, and buy funds through a US brokerage account instead.
Is assurance-vie a problem for Americans in France?
It can be, and this is the one area where practitioners genuinely disagree. Most assurance-vie contracts don’t meet the US definition of life insurance, because the death benefit is barely above the savings value. The contract can then be treated as a non-qualifying policy whose growth is taxed each year as ordinary income. Some advisers go further for the unités de compte part and look through to the funds inside as PFICs; others report it as a foreign annuity and tax it only on withdrawal.
Our lean: we treat most contracts as non-qualifying insurance and report the yearly increase, and we look through to the funds where you picked them yourself. A contract held entirely in the fonds euros is the simplest case. Whichever position is taken, it has to stay the same every year. One piece of good news: the treaty covers the 1% US excise tax on premiums paid to foreign insurers, so premiums to a French insurer are generally exempt from it.
Before you open anything at the bank
Tell your conseiller you’re American and ask what the product is before you sign. A plain compte courant, shares held directly, or a US brokerage account are easy on a US return. A Livret A costs you a little US tax. French funds, a PEA full of ETFs, and unit-linked assurance-vie cost real money and paperwork every year.
How are French pensions, US pensions and Social Security handled?
Better than in most countries. Under Article 18(1)(b), which the saving clause doesn’t override, a French social security pension paid to a US citizen living in France is taxable only in France. That covers the basic régime général pension and, on the usual reading, the mandatory AGIRC-ARRCO top-up too. Your US Social Security, going the other way, is taxable only in the US.
Private pensions are different. A PER payout or an employer’s supplementary scheme is taxed by the US with credit for any French tax. For a 401(k) or IRA built while you worked in the US, the US taxes withdrawals under its normal rules and France credits away its own tax under Article 24. Roth withdrawals are less clear on the French side, so we coordinate with your French preparer before you take one.
The totalization agreement means you pay into one social security system, not both. Employees of French companies pay French contributions. If a US employer sends you to France for up to five years you can usually stay in US Social Security with a certificate of coverage. Micro-entrepreneurs and other self-employed people living in France pay URSSAF and attach a French certificate to the 1040 to avoid US self-employment tax.
What about owning property in France or through an SCI?
Renting out a French flat means reporting the rent on your 1040 with depreciation. French tax on it, including social charges at 17.2%, is creditable. Selling your main home is exempt from French tax, but the US gain is worked out in dollars from purchase to sale. The $250,000 exclusion ($500,000 for a couple filing jointly) usually covers it, though a big move in the euro can create a gain on paper, and paying off a euro mortgage can create a separate currency gain.
An SCI, the société civile immobilière families use to hold property, is usually a partnership for US purposes, since its members don’t have limited liability. That often means Form 8865 on top of the rental figures. IFI, the wealth tax on French real estate above €1.3 million net on 1 January, isn’t an income tax and gets no US credit.
Which French accounts do I report, and what about accidental Americans?
If your non-US accounts together topped $10,000 at any point in 2025, you file an FBAR listing every account, including the Livret A, the PEA and any assurance-vie with a cash value. Form 8938 applies on top once foreign financial assets pass $200,000 at year-end or $300,000 at any time ($400,000 or $600,000 if married filing jointly). France has a mirror rule: residents declare foreign accounts, US bank and brokerage accounts included, on Form 3916 with the 2042, and the fine is €1,500 per undeclared account.
French banks report their US clients to the IRS under FATCA and ask for a US tax number, and some have threatened to close accounts without one. That has fallen hardest on accidental Americans, and the Association des Américains Accidentels has spent years fighting it. If that’s you, the practical path is usually a Social Security number, then the Streamlined procedure: three years of returns and six years of FBARs. In our experience that shows little or no tax for someone whose income has all been French.
Married to a French citizen, or PACSed?
A PACS isn’t a marriage for the IRS, so you file single or head of household. If you’re married to a non-American, you normally file married filing separately (the $5 threshold applies) unless you elect to treat your spouse as a US resident and file jointly. That election pulls their worldwide income, and often their French funds, into the US system, so we run the numbers before recommending it.
What we’d do for you
We’d start with your 2042 and avis d’imposition, credit French income tax and CSG/CRDS against your salary, and go through your bank statements account by account, because the savings side is where the US bill usually comes from. If you left a US state recently, we check whether it still considers you a resident (see our state tax guide). For the rules that apply in every country, our US expat tax guide has the detail.