“Alexis, my company is transferring me to New York for four years. I'm told my French assurance-vie will become a tax nightmare once I'm there, and that my children who stay in France will be taxed twice on my estate. What's true?”
The United States is, as of 31 December 2025, the second-largest destination for French nationals abroad with 168,529 people on the consular register, and the fastest-growing of the major destinations (+5.34% in one year). It is also the country where a poorly prepared move costs the most.
The reason comes down to two words: tax citizenship. The United States taxes its citizens and permanent residents on their worldwide income, wherever they live, and the France–US tax treaty expressly confirms this through its saving clause. A French national who becomes a US tax resident enters a system that does not reason like ours, and which treats several of our most common savings products as unknown tax objects.
At Balmont Conseil, we do not approach this subject in generalities. We start from your actual assets, contract by contract, and tell you what needs to be reallocated before departure — because afterwards, most doors have already closed.
1. Why seek expert wealth management in the United States?
Three issues need to be addressed, in this order.
- The fate of your French savings contracts. Assurance-vie, equity savings plan (PEA), capitalisation contract, fund units: the question is not whether they are “good” or “bad”, but how the US tax authorities classify them once you fall under their jurisdiction. That classification governs both taxation and reporting obligations, and the penalties for the latter bear no comparison with ours.
- The timing of departure. Crossing the thresholds of Article 167 bis of the French Tax Code (theexit tax), the date on which your French tax domicile ends within the meaning of Article 4 B, the handling of unrealised capital gains: these decisions are made before the move, not during it.
- Estate transfer to France. There is a France–US estate tax treaty — a stroke of luck, and an exception. You still need to know what it covers and, above all, what it does not neutralise.
- French property you keep. Rents, income tax at the non-resident minimum rate, social charges, IFI (real estate wealth tax): ownership continues, the taxation changes.
2. The France ↔ United States framework in five verified points
Before any recommendation, here is the applicable legal framework, verified against official sources as of 15 September 2026. These five lines determine most of your situation.
| French nationals on the register | 168,529 as of 31 December 2025 (+5.34% year on year). Second-largest destination worldwide. |
| Income tax treaty | Yes — treaty of 31 August 1994 (Official Journal of 22 March 1996), amended by the protocols of 8 December 2004 and 13 January 2009. |
| Estate tax treaty | Yes — treaty of 24 November 1978 (Official Journal of 1 October 1980), amended by the protocol of 8 December 2004. It covers estates and gifts. |
| Exit tax — deferral of payment | Automatic deferral of payment. The United States and France share an exchange-of-information clause and an assistance-in-collection clause for income tax. |
| CSG and CRDS on property income and capital gains | 17.2%. The CSG and CRDS exemption is reserved for people covered by a compulsory scheme of a European Economic Area state, Switzerland or the United Kingdom. The France–US social security agreement does not extend it to US residents. |
The “exit tax” line deserves a comment. An administrative list drawn up in 2012, still widely copied online, excluded the United States from automatic deferral and made deferral conditional on providing guarantees. That list is out of date. The authoritative list, as of 8 October 2025, places the United States among the states that qualify for automatic deferral for income tax. We check this point in every file, because it changes the cash position at departure.
The “social charges” line is the one that surprises people most. Many people leaving believe that by leaving France they leave the CSG behind. That is true for those covered by a European scheme: they bear only the 7.5% solidarity levy. It is not true in the United States: on French-source property income and real estate capital gains, the full 17.2% rate remains due.
3. Our services: 360° support for expatriates and investors
Our work covers three areas, in the order in which they shape your decisions.
Wealth audit before departure
We inventory your assets line by line: savings wrappers, property, company shares, employee savings schemes, pension rights. For each, we answer three questions — what becomes of it for tax purposes once you fall under the US tax authorities, what reporting obligation it triggers, and whether to reallocate it before departure or keep it.
It is at this stage that the fate of French assurance-vie is decided. We will not tell you to close it on principle: we will tell you what keeping it actually entails, and we will compare it with portable solutions, foremost among which is the Luxembourg assurance-vie contract, designed from the outset to follow a policyholder who changes country.
- Mapping of your savings wrappers and their real portability.
- Costing of the Article 167 bis thresholds (French Tax Code) and of the optimal departure timetable.
- Inventory of the French reporting obligations that remain after departure.
Structuring estate transfer France ↔ United States
The 1978 estate tax treaty allocates taxation according to the nature and location of assets: real property is taxable in the state where it is located, and other assets in principle follow the domicile or citizenship of the deceased or the donor. It also provides for a reciprocal tax credit.
It does not, however, do away with Article 750 ter of the French Tax Code, paragraph 3 of which makes taxable in France all assets received, wherever they are located, provided the heir or donee is domiciled in France on the date of transfer and has been for at least six of the previous ten years. If you leave and your children stay, this rule will decide their bill. We calculate it beforehand, not afterwards.
- Reading the 1978 treaty as applied to the make-up of your assets.
- Calculation of Article 750 ter for each heir, according to their own domicile.
- Alignment of beneficiary clauses with the inheritance law of the state of residence.
Management of wealth remaining in France
Your French assets continue to exist and to generate income. We handle their tax reporting and their reallocation: taxation of property income at the non-resident minimum rate under Article 197 A of the French Tax Code — with the option for the average rate when it is more favourable — the IFI (real estate wealth tax), and the choice between keeping, reallocating or contributing them to a holding structure.
This follow-up is kept in your client area, which stores documents, dates and decisions. It is also what allows you, the day the tax authorities ask a question, to answer with a file rather than with memories.
4. Methodology: our way of working
We work in four stages, and at each stage you know where you stand.
- The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
- The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
- The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.
5. What the firm offers you
What concretely sets our work apart.
- Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
- A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
- Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.
Frequently asked questions — United States
Should I close my French assurance-vie policy before leaving for the United States?
Not necessarily, and certainly not as a reflex. The right question is how the US tax authorities will classify your contract, given its composition, and the reporting obligations that follow. This analysis is carried out with a professional licensed in the United States, and we help you frame it in the right terms.
What we can state without reservation is that a surrender decided after you settle there will not cost the same as a reallocation prepared before departure. This is why this subject opens the file rather than closing it.
Will the exit tax require me to pay immediately?
No, provided the deferral of payment applies. For a move to the United States, the administrative list in force as of 8 October 2025 grants automatic deferral for income tax: no guarantee to provide, no tax representative to appoint.
What remains are the reporting obligations, which do not disappear, and the annual follow-up until the tax is discharged. We handle them for you.
Will my children who stayed in France be taxed on what I pass on to them from the United States?
The answer lies in Article 750 ter of the French Tax Code, and it depends on their domicile, not yours. If an heir is domiciled in France on the day of the transfer and has been for at least six of the previous ten years, France taxes all the assets they receive, wherever they are located.
The 1978 estate tax treaty allocates taxing rights between the two states and provides for a tax credit, which considerably eases the situation compared with countries that have no treaty. It does not remove the need to do the calculation in advance, heir by heir.
Will I still pay CSG on my French rental income?
Yes. The CSG and CRDS exemption introduced in 2019 applies to people covered by a compulsory social security scheme of a European Economic Area state, Switzerland or the United Kingdom. A US resident falls outside this scope, despite the France–US social security agreement, which deals with pension rights and not with social contributions.
On your French-source property income and real estate capital gains, the applicable rate therefore remains 17.2%, not the 7.5% solidarity levy that applies to expatriates in Europe.
How long does it take to prepare a departure properly?
Allow three to six months for a standard set of assets. Most of the work lies in making the reallocations in the right order and on the right date: some steps lose all value once your tax domicile has moved.
If your departure is sooner, tell us straight away: we will then prioritise what must be dealt with beforehand and what can safely wait.
In summary
The United States combines two particularities: a protective estate tax treaty, which is rare, and a tax system based on citizenship, which is unique among our major destinations. The first works in your favour; the second calls for serious preparation.
Between the two, the decisive variable remains timing. The reallocations that cost the least are those decided before departure.
Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.
Let's review your situation
A thirty-minute conversation is enough to know whether your plans call for reallocations before departure. You can also start with a free contract X-ray.
Other destinations
Canada · Germany · Israel · Morocco · Algeria · Netherlands · Australia · Lebanon · Côte d'Ivoire · Ireland · Greece · Monaco · Andorra · Cyprus · Jordan · Brazil · Mexico · Senegal · Tunisia — or return to all of our expatriation destinations.
