Leaving France for the United States: exit tax

Moving to the United States can trigger exit tax if you hold significant securities. Regarding the procedure, the instructions for form 2074-ETD list the United States as a country to which the deferral of payment is automatic for transfers occurring on or after January 1, 2025.

This page deals with exit tax from the perspective of leaving for the United States, and the point of entry on the American side. It does not cover departure formalities unrelated to exit tax (departure declaration, non-resident tax office), visas, US taxation of your income, or the tax treaty between the two countries. These topics are not addressed here.

Who is affected?

Notice 2074-ETD (transfers occurring in 2025) sets two cumulative conditions: the duration of domicile in France, then a holding threshold which can be reached in two ways.

The notice states: "You have been tax resident in France for at least six years during the ten years preceding the transfer." The participation test and the value test are alternative: either one is sufficient.

If the value of your portfolio is close to €800,000, the exact wording of this threshold should be checked with the official source before deciding.

Payment deferral: the United States on the list

The payment deferral can be automatic or granted upon request.

Automatic reprieve. The notice provides for this in the case of a transfer to a Member State of the European Union, or to another State or territory that has concluded the required assistance agreements with France, provided that this State is not non-cooperative within the meaning of Article 238-0 A of the French General Tax Code (CGI). It refers to a list of the States concerned, for transfers from January 1, 2025 onwards. The United States is included on this list, for transfers between Eswatini and Gabon. A transfer to the United States therefore falls under the automatic deferral, according to this list.

The information sheet on impots.gouv.fr does not list the states. It only states that the deferment is "either automatic or granted upon request." It is the explanatory note that mentions the United States.

Deferral granted upon request. The information sheet indicates that, since 2019, the deferral upon request only applies to transfers to a non-cooperative state or to a state outside the European Union without a mutual assistance agreement. According to the instructions, form 2074-ETD must be filed no later than 90 days before the transfer of your tax residence outside of France, and the deferral requires the appointment of a tax representative established in France.

A deferral of payment is a postponement of the payment of the calculated tax. This page does not describe the events that terminate the deferral, as these are not covered here.

The tax relief after 2 or 5 years

The notice and information sheet specify a period of 2 or 5 years, depending on the overall value of the securities on the date of transfer:

The notice states: "or 5 years if the total value of the securities and rights exceeds €2.57 million." The detailed conditions of the tax relief are not included here.

The rates

The notice gives the following rates for the exit tax:

• income tax: flat rate of 12.8 %; ;
• Social security contributions: 17.2% for transfers in 2025, and "For departures made in 2026, the overall rate will be 18.6%."«

These rates are those in the consulted document, which concerns transfers in 2025 and announces the rate for 2026. The document specifies that it is only indicative. The rates for other taxes are not included here.

Where and when to declare

Form 2074-ETD is only available in paper format. When deferment is automatic or no deferment is requested, it must be filed the year following the transfer, with the tax office responsible for your former residence in France, "within the same timeframe and at the same time as your income tax return (form 2042)." With an optional deferment, the first filing is made with the non-resident tax office (Noisy-le-Grand), followed by the second filing with form 2042.

The monitoring of subsequent years is covered in our pages on forms and on the annual monitoring of the deferment.

The point of entry on the American side

On its February 11, 2026, page, the IRS states the rule: a non-citizen is considered a non-resident unless they meet the green card test or the Substantial Presence Test, assessed over the calendar year. In the year of arrival, a dual-status declaration may be requested. Our page on the Substantial Presence Test details the formula for the 31 days and the weighted 183 days.

Numerical example (fictitious profile)

Situation. A fictitious executive, tax resident in France for over six years, holds securities with a total value of €3,500,000 and an unrealized taxable capital gain of €1,000,000. He moves to the United States in 2026.

Issue. He wants to know what tax is calculated initially, and whether he has to pay it right away.

Strategy. This falls under the category of automatic deferment, as the list in the notice includes the United States. Income tax of 12.8% and social security contributions of 18.6% are applied for a departure in 2026. The total value exceeds €2.57 million: the deferment period is 5 years.

Result. The calculated tax is €128,000 in income tax plus €186,000 in social security contributions, totaling €314,000, or 31.4 times the capital gain. With the same capital gain amount, a transfer in 2025 would yield €300,000 (social security contributions at 17.2 times the capital gain), or €14,000 less.

According to the notice, with an automatic deferral, this tax is not paid at the time of departure: its payment is deferred.

This profile is fictitious. The assumptions made for the calculation are: no allowances, known unrealized capital gains, and the rate specified in the notice. It does not prejudge any real-life situation.

What changes depending on your situation

• Your departure date : the rate of social security contributions depends on the year of the transfer.
• Your stake and the value of your securities : the thresholds of 50 % and 800,000 € open or close the scope of exit tax.
• The overall value of your securities : it sets the deadline at 2 years or 5 years.
• The destination state : the list in the notice concerns the United States; other destinations fall under other cases.
• Your status on the American side : the two residency tests and the dual status of the year of arrival.

No results are promised.