Wealth management in the United States

«"Alexis, my company is transferring me to New York for four years. I'm told that my French life insurance will become a tax nightmare once I'm there, and that my children who stayed in France will be taxed twice on my estate. What's true?"»

The United States is, as of December 31, 2025, the second most popular destination for French people living abroad With 168,529 registered consular residents, it is the fastest-growing destination (+5.34% in one year). It is also the country where poorly planned relocation is the most expensive.

The reason can be summed up in two words: tax citizenship. The United States taxes its citizens and permanent residents on their worldwide income, regardless of where they live, and the Franco-American tax treaty expressly confirms this through its safeguard clause. A French citizen who becomes a US tax resident enters a system that operates differently from ours and treats many of our most common savings products as unfamiliar tax entities.

At the house of Balmont Conseil, We don't approach this subject with generalities. We start with your actual assets, contract by contract, and we tell you what needs to be adjusted. Before the departure — because afterwards, most of the doors closed.

1. Why seek expertise in wealth management in the United States?

Three construction sites must be opened, and in this order.

• The fate of your French savings contracts. Life insurance, equity savings plans, capitalization contracts, mutual fund units: the question isn't whether they're "good" or "bad," but how the US tax authorities classify them once you fall under their jurisdiction. This classification determines both taxation and reporting obligations, the penalties for which are vastly different from those in our country.
• The timeline of departure. Crossing the thresholds of Article 167 bis of the General Tax Code (the’exit tax), the date of termination of the French tax residence within the meaning of Article 4 B, the arbitration of unrealized capital gains: these decisions are made before the move, not during.
• Transmission to France. A Franco-American inheritance treaty exists—it's a blessing, and an exception. But it's essential to understand what it covers and, more importantly, what it doesn't eliminate.
• French real estate preserved. Rent, income tax at the minimum rate for non-residents, social security contributions, real estate wealth tax: ownership continues, taxation changes.

2. The France ↔ United States framework in five verified points

Before making any recommendations, here is the applicable legal framework, verified in official sources as of September 15, 2026. These five lines determine the essence of your situation.

The line "exit tax" deserves a mention. An administrative list established in 2012, still widely copied online, excluded the United States from automatic tax deferral and made it contingent upon the provision of guarantees. This list is outdated. The current list, as of October 8, 2025, places the United States among the states that automatically qualify for tax deferral. We verify this point in every case, as it significantly impacts the initial cash flow.

The "social security contributions" line is the one that is most surprising. Many people leaving France believe that they will no longer be subject to the CSG (General Social Contribution). This is true for those affiliated with a European social security scheme: they will only be liable for the solidarity levy of 7.5%. This is not true in the United States: on French-source rental income and capital gains, the full rate of 17.2% remains due.

3. Our services: 360° support for expatriates and investors

Our intervention unfolds on three levels, in the order in which they influence your decisions.

Asset audit before departure

We inventory your assets line by line: savings accounts, real estate, shares, employee savings plans, pension rights. For each, we answer three questions — what happens to it for tax purposes once you become subject to US tax authorities, what reporting obligations does it trigger, and should you reallocate it before leaving or keep it?.

It is at this stage that the fate of French life insurance 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 life insurance contract, designed from the outset to follow a subscriber who changes countries.

• Mapping of envelopes and their actual portability.
• Calculation of the thresholds of article 167 bis of the CGI and the optimal departure schedule.
• List of French reporting obligations that remain despite departure.

Structuring the transmission France ↔ United States

The 1978 Succession Convention allocates taxation according to the nature and location of assets: real estate is taxable in the state where it is situated, and other assets generally follow the domicile or citizenship of the deceased or the donor. It also provides for a reciprocal tax credit.

However, this does not eliminate article 750 ter of the general tax code, paragraph 3 of which makes taxable in France all goods received, wherever they are located, This applies provided the heir or donee is domiciled in France on the date of the transfer and has been so for at least six of the ten preceding years. If you leave and your children remain, this rule will determine their bill. We calculate it beforehand, not afterward.

• Reading the 1978 convention as applied to your asset composition.
• Calculation of article 750 ter for each heir, according to their own domicile.
• Interaction of beneficiary clauses with the inheritance law of the State of residence.

Management of heritage remaining in France

Your French assets continue to exist and generate income. We take care of their tax reporting and allocation: taxation of property income at the minimum rate for non-residents under Article 197 A of the French General Tax Code — with the option for the average rate when it is more favorable —, real estate wealth tax, and the choice between retention, allocation or contribution to a structure.

This tracking is ensured in your client area, which stores documents, dates, and decisions. This also allows you, when the administration asks a question, to respond with a file rather than relying on memories.

4. Methodology: our way of working

We work in four stages, and you know where you are at each stage.

1. The initial assessment. We assess your actual situation: composition of assets, project timeline, situation of each member of the household, and tax domicile of your heirs — because it is theirs that dictates, not yours.
2. The applicable reference framework. We establish, source by source and with its date, the framework that concerns you. What we do not know, we write "to be confirmed" — never anything else.
3. The arbitrations. We present you with the numerical options, along with their respective consequences, and you decide. Heritage engineering comes after the decision, not before.
4. The follow-up. An annual review, offered free of charge, which verifies that the framework has not changed — the conventions are modified, the attractiveness schemes are eliminated, the thresholds change.

5. What the firm offers you

This is what specifically distinguishes our intervention.

• Sources, not claims. Each item in your file has its reference number and date. You can check. This is the only way to work on a subject where most of the information available online is outdated.
• A single point of contact in France. We coordinate with your local advisors, we do not replace them: the internal tax regulations of the host country are handled by a qualified professional on site. Our role is to maintain overall consistency and to defend the French side of the case.
• Fees that are easy to understand. Firm fees: €500 including VAT per hour. Annual follow-up is included. No hidden kickbacks, no performance-based billing.

Frequently Asked Questions in the United States

Should I close my French life insurance policy before leaving for the United States?

Not necessarily, and certainly not automatically. The real question is how the US tax authorities will classify it. your contract, taking into account its composition and the resulting reporting obligations. This analysis is conducted with a licensed professional in the United States, and we help you formulate it correctly.

What we can state without reservation is that a buyout decided after the move will not have the same cost as a decision made before departure. This is why this issue opens the case rather than closing it.

Will the exit tax require me to pay immediately?

No, not if the payment deferral applies. For departures to the United States, the administrative list in effect as of October 8, 2025, opens the automatic reprieve In matters of income tax: no guarantee to be provided, nor tax representative to be appointed.

The reporting obligations remain, and they do not disappear, along with the annual monitoring until the tax relief is granted. We handle these for you.

Will my children who remained in France be taxed on what I send them from the United States?

Article 750 ter of the General Tax Code provides the answer, and it answers based on their domicile, not yours. If an heir is domiciled in France on the day of the transfer and has been domiciled there for at least six years during the previous ten years, France taxes all the assets he receives, wherever they are located.

The 1978 inheritance treaty governs the distribution of assets between the two states and provides for a tax credit, which significantly mitigates the situation compared to countries without a treaty. However, it does not eliminate the need to perform the calculations beforehand, heir by heir.

Will I continue to pay CSG on my French rents?

Yes. The exemption from CSG and CRDS introduced in 2019 applies to individuals affiliated with a mandatory social security scheme in a country within the European Economic Area, Switzerland, or the United Kingdom. Residents of the United States are not included in this exemption, despite the Franco-American social security agreement, which covers pension rights and not social security contributions.

Therefore, the applicable rate remains the same for your French-source rental income and capital gains on real estate. 17.2 %, and not the solidarity levy of 7.5 % which benefits expatriates in Europe.

How long does it take to prepare for a departure properly?

Allow three to six months for managing current assets. The main task is to make the necessary adjustments in the right order and at the right time: some actions become pointless once the tax residence has been transferred.

If your departure is closer, please tell us right away: we will then prioritize what needs to be dealt with first, and what can wait without harm.

In summary

The United States has two distinctive features: a protective inheritance law, which is rare, and a tax system based on citizenship, which is unique among our major destinations. The first point works in your favor, the second requires careful preparation.

Between the two, the decisive variable remains the schedule. The least costly trade-offs are those decided before departure.

Firm's fees: €500 including VAT per hour. Annual follow-up is offered.

Let's review your situation

A thirty-minute exchange is enough to determine if your project requires any adjustments before departure. You can also start with a Free X-ray of your contracts.

Other destinations

Canada · Germany · Israel · Morocco · Algeria · The Netherlands · Australia · Lebanon · Ivory Coast · Ireland · Greece · Monaco · Andorra · Cyprus — or return to all of our Expatriation destinations.