US-France Tax Treaty: What Americans Living in France Pay, and Where (2026)

Americans who move to France do not pay tax twice on the same income, as long as the 1994 US-France tax treaty is applied correctly. France taxes its residents on worldwide income, but it gives up its tax on most of what the treaty reserves to the US, such as Social Security and payments from US retirement plans. The US keeps taxing its citizens wherever they live, with a credit for French tax. The real cost is in a few details: French social charges of 18.6% on investment income in 2026, the sale of a US home after the move, and the 3.8% US net investment income tax, which French tax cannot offset.

Key facts

Income or question	Short answer
Which text applies	The treaty of 31 August 1994, amended in 2004 and 2009
Does the US still tax a citizen living in France?	Yes (saving clause, art. 29), with a credit for French tax
Salary for work done in France	Taxable in France, even if the employer is American (art. 15)
US Social Security	Taxable only in the US (art. 18). France uses it only to set your rate
401(k), IRA	As a rule, taxable only in the US on withdrawal (art. 18)
US dividends	15% US withholding, credited against the 31.4% French flat tax
Rent from a US property	Taxed in the US; in France, counted for the rate only
Sale of a US property	Taxable in both countries; France may collect a top-up
US bank accounts	Reported every year in France (form 3916); €1,500 fine per missed account

Three questions to see where you stand

Is France now your home? One test is enough under French law (art. 4 B CGI): your home or main place of stay, your main work, or the centre of your economic interests. A US passport or green card does not keep you out of French residence.
Are you a US citizen or green card holder? If yes, you file in both countries every year. If not, the US generally stops taxing work you do outside the US.
What income stays in the US? Social Security, a 401(k) or IRA, a portfolio, rent, a house you plan to sell. Each follows a different rule, and the house is the one that most often costs money.

Yes to the first question means France taxes your worldwide income from the day you settle. The other two decide what the treaty takes back out.

Why US citizens still file in the US

The US taxes its citizens on worldwide income wherever they live, and the treaty lets it do so "as if the Convention had not come into effect" (art. 29(2)). The treaty only decides who taxes first and who gives the credit:

French-source income (salary for work in France, rent from a Paris flat): France taxes first, the US gives a credit.
Certain US-source income (dividends from listed US companies, US interest): the reverse. France gives a credit equal to its own tax, so no French income tax and no social charges, provided you prove your US filings are up to date (art. 24(1)(b)).
Social Security and US pensions stay protected even for citizens (art. 29(3)).

Working from France for a US employer

Salary is taxed where the work is physically done. Live in Paris and work for a New York company, and your salary is taxable in France, even if it is paid in dollars into a US account. The 183-day rule does not help: it covers short trips, not a resident working from home.

You declare it in France with form 2047. As a rule, the US employer must withhold French tax at source.
An employee posted by a US employer can stay in the US social security system for up to 5 years, with a certificate of coverage. Otherwise, French contributions apply.
An employee who habitually signs contracts in France for the company can create a taxable presence for the employer here (art. 5(5)).

If a company established in France hires or transfers you from abroad, the impatriate regime can exempt part of your pay for 8 years. A remote employee of a US company is generally not eligible.

Dividends, interest and gains on shares

For a French resident, investment income is taxable in France wherever it comes from. In 2026 the flat tax is 31.4% (12.8% income tax plus 18.6% social charges).

Example. You are not a US citizen and receive €10,000 of US dividends. The US withholds €1,500. France calculates €3,140 and deducts the €1,500 credit: you pay €1,640 in France. Total cost: 31.4%, with no double tax.

For a US citizen, it works the other way on dividends from listed US companies: France gives up its tax, provided US compliance is shown, and the US taxes under its own rules. One gap remains: on 31 August 2026, a US federal appeals court held that French tax cannot offset the 3.8% net investment income tax.

Social Security, 401(k) and IRA: the generous part

Since the 2004 and 2009 amendments, US Social Security and payments from a retirement plan set up in the US for past employment are taxable only in the US (art. 18(1)), including for US citizens. France cannot tax them. You report them, they are cancelled out, and their only effect is to raise the rate on your other income. No French social charges are due on them.

401(k) and employer plans: covered.
Traditional IRA: usually treated the same way, but an IRA funded outside any employment can be argued about.
Roth IRA: not named in the treaty. In 2020 the French government answered a senator that payments from US retirement plans are taxable only in the US, without distinguishing between plans. That answer is not in the official tax guidance, so a large withdrawal should be documented first.

Some residents have still been charged French social charges on US pensions. Your tax notice is worth checking.

A US home: renting is fine, selling late is the trap

Rent from a US property is taxed in the US. France counts it for the rate only.

A sale works differently. The gain is taxable in the US, but France can tax it too, and only credits the US tax actually paid (art. 24(1)(a)(iii)). If the French tax is higher, you pay the difference in France. The French main-home exemption only applies if the house is still your main home when sold, or was sold within a normal period (usually one year) after you left it, without being rented in between.

Example. A couple moves to Paris, rents out their US house, and sells it two years later with a €200,000 gain after 10 years of ownership. In the US, the main-home exclusion may wipe out the tax. In France, the house is no longer their main home: about €64,000 of tax after holding-period relief, with no US tax to credit. Sold within a year of the move, without renting it out, the same sale could cost nothing in France.

Before you move: five things to settle

Your arrival date. It starts French taxation of your worldwide income, and the 5 years during which a US citizen without French nationality pays French wealth tax (IFI) only on French real estate.
Pending sales. A house, a business or a portfolio is not taxed the same way before and after arrival.
US accounts. Every bank or brokerage account is reported each year with the French return (form 3916), even if it earns nothing.
French investments for US citizens. French funds and some life insurance contracts can be treated very harshly by the IRS. Check with a US tax adviser before investing.
Estate planning. A separate 1978 US-France treaty and your marital regime decide what your heirs will pay. See French inheritance tax.

When it gets complicated

Both countries treat you as resident. The treaty's tie-breaker turns on facts (home, family, economic ties) that have to be documented.
You are a US citizen with large US-source income. The French credit depends on proving US compliance, and its interaction with the US credit is one of the most technical parts of the treaty.
You plan a large 401(k), IRA or Roth withdrawal. The French treatment depends on the plan, and some points are unsettled.
You work in France for a US company with no French entity. Withholding, social security and the employer's tax exposure have to be handled together.
You hold a US LLC, trust or company. France and the US do not always classify it the same way, which can create unexpected tax.
You missed US accounts or income in past years. Correcting it yourself usually costs less than an audit.

Moving to France with income, accounts or property in the US? A short consultation is enough to see how each piece will be taxed and what to settle before your arrival date.

Frequently asked questions

Do Americans living in France pay tax twice?

As a rule, no, if the treaty is applied correctly. Some residual double tax exists, for example on the 3.8% net investment income tax or on the sale of a US home after the move.

Is US Social Security taxed in France?

No. It is taxable only in the US, including for US citizens. It is reported in France and only raises the rate on your other income.

Do I file a French return if I work remotely for a US company?

Yes, if you are a French resident. Pay for work done in France is taxable in France and reported with form 2047. A US citizen also files a US return.

Do I have to report my US bank accounts in France?

Yes, every account opened, held or closed abroad, each year, on form 3916. The fine is €1,500 per unreported account.

Two ways to move forward

You are preparing your move. You want to know, before moving, how your salary, investments, retirement plans and US property will be taxed, and what to settle before your arrival date. Book a consultation.

You already live in France. You have US income, accounts or a sale to report, or doubts about what you paid in recent years. Describe your situation and you will receive a proposal for full assistance.

General information under French law as at 2 November 2026. It is not legal advice for your situation. US tax rules require a US adviser.

General information under French law, up to date on the date of review. It does not replace advice on your own situation.