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Americans in France For Members

Eight hard facts Americans should be aware of before moving to France

Genevieve Mansfield
Genevieve Mansfield - [email protected]
Eight hard facts Americans should be aware of before moving to France
A person waves French and American flags in 2017 on board a cruise liner (the RMS Queen Mary 2) that goes between Saint-Nazaire, France and to New York city. (Photo by LOIC VENANCE / AFP)

France may be a lovely place for a vacation, but moving here permanently is a different story. Here are some hard truths Americans should consider before making that decision.

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You've probably already heard about the struggles of navigating French bureaucracy as a foreigner, the importance of learning the French language, the complexities of residency cards and visas and - if you want to move to Paris - the difficulty in finding somewhere to live.

If you are not a dual citizen, then you will also need some kind of visa or residency card to spend more than 90 days out of every 180 here.

READ MORE: EXPLAINED: What type of French visa do you need?

The above things affect most people moving to France, but there are some specific challenges for Americans.

Now we're not trying to put you off - many Americans live very happy lives in France - but it's as well to be aware of potential problems before you move.

Banking 

Americans often have problems opening a French account because of the Fatca legislation, or the Foreign Account Tax Compliance Act, which obliges foreign banks to report back to the US tax office on any assets held in these accounts by US taxpayers. 

So don't be surprised if you are turned down flat when you try to open an account, even if you have plenty of money and an excellent credit rating. You can find a full explanation of the problem, and what to do about it, HERE

Tax 

Don't imagine that the IRS will let you go just because you have left the country - because of the American policy of citizenship-based taxation and you must continue to file US taxes until you either die or renounce your US citizenship.

READ MORE: Divorce, stress and fines: How citizenship-based taxation affects Americans in France

However, just because you have already filed with the IRS doesn't mean that you are exempt from the French tax system, if you are living in France you are counted as French tax resident; yes, you're probably going to end up doing two tax returns per year - sorry, we didn't make the rules! 

According to the French government, you are a tax resident (and therefore you must file a yearly declaration) if you meet ANY of the following conditions;

  • Live in France 
  • Working or earning any kind of income in France
  • Have the centre of your economic interests in France

The government's definition of living in France is that France is your 'main place of residence' and it defines this as 'you stay there more than six months of the year'.

If you are seeking to avoid filing a tax declaration in France, limiting yourself to under six months a year is not the only thing to consider. You also need to think about whether you are working in France, or whether you have your 'main investments' in France. 

Once you've established that you are resident in France, you need to be aware that everyone who lives in France must file an annual income tax declaration (déclaration des revenues) - even if they have no income in France.

Some good news though - being a French tax resident and filing the annual declaration in France doesn't necessarily mean that you will have to pay French taxes. Americans benefit from a generous tax treaty with France that keeps certain types of income (eg a US pension) out of the scope of the French taxman.

READ MORE: Ask the expert: What Americans in France need to know about 401(k) and other pensions

Investments

Citizenship-based taxation doesn't just mean filing a US tax return for the rest of your life - IRS rules also limit what you can do with your money in France, especially when it comes to life insurance and pensions.

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Popular ways that French people save for old-age, like the Assurance Vie or Plan d'Epargne de retrait are not advisable for Americans because the IRS considers them to be Passive Foreign Investment Companies (PFICs). These are not banned for Americans, but they will open up a whole world of complications with the IRS.

READ MORE: Ask the experts: What do Americans in France need to know about investments and pensions?

On the other side of the coin, Americans resident in France need to be very careful about any US-based trusts that they are beneficiaries of. French tax authorities are very suspicious of trusts, and consider them linked to tax evasion. This can lead to onerous reporting requirements and high taxes (upon distribution).

Estate planning

France has both complicated laws on inheritance (for example you cannot disinherit your children) and some high inheritance tax rates - ranging from 0 to 60 percent based on the person's relationship with the deceased.

In contrast to the US, it is the recipient who is responsible for paying tax (based on the amount they receive) rather than entire estate being taxed prior to distribution.

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The standard rule is that if you are considered to be a resident of France, then your entire estate, including assets located outside of France, can be subject to inheritance tax by French authorities (subject to international agreements and bilateral tax treaties).

READ MORE: Death and taxes: What you need to know about estate planning in France

It is therefore highly recommended to take advice from a lawyer and accountant licensed in both France and the US to ensure that your estate planning is legal and tax compliant in both countries.

Healthcare

While it is true that France has quality public healthcare and you can register to be part of the state system after three months of living in France, you might still find yourself paying health-related expenses.

First off, the system works via reimbursements - you pay upfront for appointments, medication and medical procedures and, if you are registered in the system, the French state reimburses you some or all of the cost.

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READ MORE: How to get a carte vitale in France and why you need one

If you move to France on a 'visitor' visa you will need to show proof of private health cover, usually for one year.

There is also a possibility you will be charged for PUMa - or protection universelle maladie.

For Americans not expecting to owe the French government anything, it can come as quite a shock and it can be even more confusing to try to parse out who owes the charge and who does not, as its application may appear random when taken at face-value.

The charge associated with PUMa is actually called the 'cotisation subsidiaire maladie', or CSM.

At the highest bracket, the maximum CSM charge possible as of 2024 was €22,604 per year. There are, however, many groups who are exempt from CSM charges.

Find the full explanation HERE

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Working in France

As an American, you will probably notice that French salaries are significantly lower than those in the US. On the plus side, French workers benefit from a minimum of 25 vacation days per year, plus public holidays, sick pay and parental leave, plus it is harder to be fired here.

READ MORE: The best job search websites in France and tips for using them

You will also have to familiarise yourself with the world of French residency cards, assuming you are not an EU/French dual national or the spouse of one, since only certain residency cards give you the right to work in France.

If you don't already have the right to work in France, then your employer may need to apply for a work permit on your behalf. 

This extra admin burden means that employers may be less willing to hire Americans who do not already have the right to work in France.

READ MORE: Three things to know about work permits in France

The grey area of working remotely from France

On the topic of work, it's worth pointing out that France does not have a specific 'digital nomad' visa.

READ MORE: Digital nomad: What are the rules on working remotely from France?

Instead, freelancers who work online or remotely are often recommended to apply for the 'entrepreneur' visa, but to qualify for this you will need a business plan to prove that you will be able to support yourself financially - or evidence of savings. Generally, you should offer any and all proof that your freelancing activity will provide sufficient income at least equivalent to France's legal minimum wage.

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Many Americans move to France a 'visitor' visa with hopes of continuing to work remotely for a company based in the US. However, this is a legal grey area, as the visitor visa requires that applicants declare that they will not "exercise a professional activity in France".

If you're thinking of working remotely from France, you may be able to do so, but you will need to consider the implications it will have on other parts of your life here - from tax to social security contributions and insurance.

READ MORE: Ask the experts: What's the deal with remote working and France's visitor visa?

Driver's licence

If you drive, you will need to swap your American licence for a French one within one year of moving here.

READ ALSO: Is it illegal to drive on a foreign licence if you live in France?

Americans face an extra hurdle here - only certain states have a reciprocal agreement with France. If your state does not have one, then you will have to take a French driving test in order to get a licence in France. 

The following US States have licence swap agreements with France:

Delaware*,  Maryland*, Ohio*, Pennsylvania**, Virginia*, South Carolina, Massachusetts,  New Hampshire, Illinois, Iowa, Michigan, Wisconsin*, Arkansas*, Oklahoma*, Texas*, Colorado*, Florida**, Connecticut**
* Swap for Permis B licences in France, ** Swap for Permis A and/or B licences in France - see below for what this means

Buying French property

The good news is that there are no official rules in France against non French-citizens purchasing property, neither is there any requirement to be resident in the country in order to buy property. In fact, foreign second-home owners make up a small but significant slice of the property market.

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Buying a home will be significantly simpler if you are paying cash, but if you need a mortgage then you will likely run into some challenges, linked to those Fatca rules that also make it harder to get a bank account.

READ MORE: French property: How to get a mortgage in France

When it comes time to purchase, you should know that the process will be very different from the United States.

In contrast to the US system of having a realtor who guides you through the entire process, in France - as in most of Europe - buyers are expected to do much work of the house-hunting work themselves. 

Once you have found a property you want to buy, then you need to allot time for all of the different steps, as it can take several months. You should also familiarise yourself with French property taxes.

The Local has an "Americans in France" monthly newsletter for members, featuring all the news and practical information you need as an American resident, visitor or second-home owner in France. You can sign up to receive it directly to your inbox.

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Comments (3)

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Brian Knowlton 2024/06/22 08:42
Very helpful listing of the major issues facing Americans hoping to live in France. Thanks!!
Timothy 2024/06/21 21:15
You continue to be domiciled in the last US state you lived it. So you vote there. And probably will continue to pay state income tax there.
Julia Brandenburg 2024/06/21 16:42
I recentlty read an interesting blog online that allows an American to stay in France an additional 90 days beyond the Schengen limit. There is a post-WW2 agreement that has never was cancelled. If this is valid, it would be a lot easier then getting a 6 month visa. Anyone aware of this 1949 agreement? See https://www.nomadicmatt.com/travel-blogs/how-to-legally-stay-in-europe-for-more-than-90-days/

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