French Tax Counsel for U.S. Citizens & American Expats
We have built a recognized expertise for U.S. citizens, Green Card holders, and American expats navigating the French tax system: FBAR, FATCA, Franco-American Tax Conventions of November 24, 1978 and August 31, 1994 for the Avoidance of Double Taxation, and CPA coordination. Bilingual practice based in Nice.
AT A GLANCE
All nationalities
Residents & non-residents · Deep expertise for American clients
EN · FR · Based in Nice
Recognized expertise
A specialized practice for Americans in France,
built over a decade
More than half the French income tax returns we file every year are for U.S. citizens, Green Card holders, and American expats, whether French tax residents or non-residents with French-source income. This is not a side service. It is a core part of what we do.
FBAR · FATCA
Convention 1978
Convention 1994
CPA Coordination
IFI · Trust Structures
2026 Jurisprudence
Bilingual EN / FR
Our practice combines deep knowledge of the French tax code with a thorough command of U.S. reporting obligations — FBAR, FATCA, the Franco-American Tax Convention of 1994, and direct coordination with U.S. CPAs and tax attorneys. We operate fully bilingually, with no intermediary between you and your French obligations.
Our Practice
A Practice Built Around American Clients
More than half the French income tax returns we file every year are for American clients — whether French tax residents or non-residents with French-source income. This is not a side service. It is a core part of what we do.
French Income Tax Returns
Form 2042 and all annexes — for French residents and non-residents with French-source income. Full compliance with DGFiP requirements.
Real Estate Income
Furnished and unfurnished rental income. Analysis of prélèvements sociaux exemptions available under the Franco-American Tax Convention of August 31, 1994.
Capital Gains
French real property and securities disposals. Treaty analysis, taux forfaitaire, applicable exemptions, and coordination with U.S. reporting obligations.
Wealth Tax (IFI)
Filing obligations for non-residents holding French real estate above €1.3M. Treaty-based analysis of taxable base, deductions, and reporting thresholds.
FBAR & FATCA Coordination
Foreign financial account reporting compliance. We coordinate with your U.S. CPA or attorney to ensure aligned positions across both jurisdictions.
Coordination with U.S. Advisors
We work in both English and French. We liaise directly with your stateside CPA, tax attorney, or trust officer to ensure full consistency in cross-border positions.
The 1994 convention
The Franco-American Tax Convention — August 31, 1994
The Franco-American Tax Convention of August 31, 1994 (as amended by the 2009 Protocol) is widely regarded as one of the most favorable bilateral tax treaties in the world for U.S. citizens.
Unlike most French tax treaties, it contains specific provisions that go well beyond mere double taxation avoidance — granting U.S. nationals residing in France a set of unique advantages on their U.S.-source income that are unavailable under any other French convention.
The complexity of U.S. obligations — FBAR, FATCA, the interplay between the IRS and the DGFiP, and the unique provisions of the 1994 Convention — requires a level of technical precision and cross-border coordination that we have made a core part of our practice.
• Équipe dédiée aux transmissions
Une équipe spécialisée, mobilisant droit des sociétés, fiscal, social et immobilier commercial.
• Double Taxation Relief on U.S.-Source Income
Specific treaty provisions prevent double taxation on dividends, interest, pensions, and capital gains — with favorable allocation rules between jurisdictions.
• IFI / Wealth Tax Treaty Positions
Treaty coverage of wealth tax obligations — including the unresolved question raised by the 2026 rulings on U.S. trust structures and Article 990 J CGI.
• Green Card Holders & Former U.S. Residents
Specific treaty provisions address the overlapping obligations of Green Card holders — a particularly complex compliance profile under both French and U.S. law.
Annual Campaign
Key French Filing Deadlines
French income tax returns must be filed each year. Deadlines are set annually by the DGFiP upon opening of the campaign, typically in April.
2026 Filing Calendar
Online deadline — Zone 1
Period
Milestone
Applies to
EARLY APRIL
Online filing opens — impots.gouv.fr
All taxpayers
EARLY MAY
Online deadline — Zone 1
Non-residents · Dép. 01–19
MID-MAY
Deadline — paper returns (first return)
All paper filers
LATE MAY
Online deadline — Zone 2
Dép. 20–54
EARLY JUNE
Online deadline — Zone 3
Dép. 55–976
Critical for American clients : Non-residents file under Zone 1 — the earliest online deadline, falling in early May. Many U.S. clients are unaware of this and miss the deadline. Cross-border returns involving rental income, capital gains, or treaty positions require careful preparation well in advance.
Legal alert - February & March 2026
U.S. Trusts & French Wealth Tax:
A Legal Storm Is Brewing
COUR DE CASSATION · FEBRUARY 11, 2026 · CASS. COM., N° 23-14.305
Treaty Protection Against Article 990 J CGI Questioned
France’s Commercial Supreme Court quashed a Paris Court of Appeal judgment that had granted full treaty protection against the Article 990 J CGI levy — a sui generis 1.5% annual tax on undisclosed trust assets. The case is remanded to the Paris Court of Appeal.
CONSEIL D'ÉTAT · MARCH 13, 2026 · SEPARATE TRUST CASE
Article 990 J Falls Within Treaty Scope — Contradicting Tax Authorities
The Conseil d’État ruled that Article 990 J does fall within the scope of bilateral tax treaties — directly contradicting the French tax authorities’ longstanding doctrine and the implicit skepticism of the Cour de Cassation.
France’s two supreme courts are now pointing in opposite directions on the same question — leaving U.S. nationals with French trust exposure in a zone of profound legal uncertainty.
Why This Matters for Americans Specifically
FULL LEVY EXPOSURE
U.S. trust assets held by French residents face full exposure to the 1.5% annual levy with no treaty shield against double taxation if treaty protection is excluded.
EXTENDED LIMITATIONS PERIOD
Limitation periods may be extended to 10 years where undeclared foreign assets are involved.
SEVERE PENALTIES
Penalties of up to 80% apply in cases of willful non-disclosure of foreign trust structures.
Treaty Protection Against Article 990 J CGI Questioned
Revocable Living Trusts
Irrevocable Trusts
Dynasty Trusts
Testamentary Trusts
Any structure where a French resident acts as settlor, trustee, or beneficiary falls within the scope of these rulings.
Why This Matters for Americans Specifically
1
Map all U.S. trust structures
Identify all U.S. trust arrangements involving French residents as settlor, trustee, or beneficiary.
2
Review IFI filing history
Assess ISF/IFI filing history and applicable statutes of limitation, including the potential 10-year extended period for undeclared foreign assets.
3
Case-by-case treaty analysis
Analyze treaty coverage individually — the answer is not settled law. Each structure and each treaty requires specific analysis.
4
Consider voluntary disclosure
Evaluate voluntary disclosure strategies before the Paris Court of Appeal issues its ruling on remand.
5
Monitor the Paris Court of Appeal
The forthcoming ruling on remand will be decisive. Proactive positioning is critical — the window for voluntary planning will not remain open indefinitely.
Why our firm
A Dedicated Cross-Border Practice
01
Franco-American Expertise
Deep knowledge of both the French tax code and U.S. tax obligations, with extensive experience applying the 1994 Franco-American Tax Convention.
02
Fully Bilingual Team
All advice, filings, and correspondence delivered in both English and French. No language barrier between you and your French obligations.
03
Strict Confidentiality
All consultations and client matters are handled under strict professional secrecy consistent with French secret professionnel obligations.
04
International Coordination
We work directly with your U.S. CPA, tax attorney, or wealth manager to ensure aligned cross-border positions and eliminate compliance gaps.
Request a Confidential Consultation
Whether you are a French resident, a non-resident with French-source income, or a foreign investor in France — our team handles your French tax return from preparation through submission.
English & French · All time zones
Nice, France — Advising internationally
All inquiries are strictly confidential — protected under French secret professionnel obligations.