The United States taxes its citizens on worldwide income, regardless of where they live. A US citizen who relocates to France remains fully subject to US federal income tax on all income earned anywhere in the world. French and US tax obligations are separate and must both be satisfied. Moving to France does not create an exemption from the US tax system.
Two mechanisms prevent actual double taxation for most US residents in France. The Foreign Earned Income Exclusion (Form 2555) can exclude up to $130,000 (2025) of foreign earned income from US income tax. The Foreign Tax Credit (Form 1116) reduces US tax dollar-for-dollar by creditable foreign taxes paid. For the majority of US residents in France, applying one or both of these mechanisms reduces US income tax liability to zero. The obligation to file Form 1040 remains regardless.
Compliance involves more than the income tax return. Americans in France with French bank accounts, investment portfolios, retirement savings plans, and business interests face additional reporting obligations under separate statutes. These obligations are administered by different agencies, carry independent penalties, and must be satisfied alongside the income tax return.
Who Must File
US citizens and resident aliens must file Form 1040 if their gross worldwide income exceeds the applicable threshold for their filing status and age.
| Filing Status | 2024 Filing Threshold |
|---|---|
| Single, under 65 | $14,600 |
| Single, 65 or older | $16,550 |
| Married Filing Jointly, both under 65 | $29,200 |
| Married Filing Jointly, one spouse 65 or older | $30,750 |
| Married Filing Jointly, both 65 or older | $32,300 |
| Married Filing Separately (any age) | $5 |
| Head of Household, under 65 | $21,900 |
Gross income for this purpose includes all worldwide sources: wages, self-employment income, interest, dividends, capital gains, rental income, and pension distributions. The threshold is tested against gross income before any exclusions or deductions, including the FEIE.
US citizens below the income threshold may still have FBAR and Form 8938 obligations. Those obligations are triggered by the value of foreign accounts and assets, not by the amount of income.
Filing Deadlines
| Situation | Deadline |
|---|---|
| Standard | April 15 |
| Living outside the US with a foreign tax home | June 15 (automatic, no request required) |
| Further extension (Form 4868) | October 15 |
| Cannot meet qualifying tests by extended deadline | Form 2350 available for additional extension |
The automatic two-month extension to June 15 applies to US citizens residing outside the US and Puerto Rico who have a tax home in a foreign country on the original due date. Attaching an explanatory statement to the return is recommended to document reliance on the extension. Interest on unpaid tax runs from April 15 regardless of which extension applies.
Key Forms
| Form | What It Does | Who Needs It |
|---|---|---|
| Form 1040 | Federal income tax return | All US citizens meeting the income threshold |
| Form 2555 | Foreign Earned Income Exclusion | US citizens with qualifying foreign earned income |
| Form 1116 | Foreign Tax Credit | US citizens with creditable foreign taxes paid or accrued |
| FinCEN Form 114 (FBAR) | Report of Foreign Bank and Financial Accounts | US persons with foreign accounts aggregating over $10,000 at any point during the year |
| Form 8938 | Statement of Specified Foreign Financial Assets | US citizens abroad with foreign financial assets exceeding $200,000 at year-end or $300,000 at any point during the year (single filer) |
Additional forms apply in more complex situations. Form 5471 covers ownership interests in French corporations. Form 8621 applies to interests in passive foreign investment companies, which includes certain French investment wrappers such as assurance-vie. Form 3520 covers transactions with foreign trusts and certain large gifts from foreign persons. Form 8865 applies to interests in French partnerships.
Self-Employment
Self-employed Americans in France are subject to income tax and self-employment tax. The Foreign Earned Income Exclusion does not eliminate self-employment tax. Self-employment tax applies to the full net self-employment income, including any amount excluded from income tax under Form 2555.
The US–France totalization agreement determines social security coverage for self-employed individuals. A self-employed American covered under the French social security system is generally exempt from US self-employment tax and pays French cotisations instead. The two systems do not apply simultaneously. Coverage status is established through a certificate of coverage issued by the applicable social security authority.
Technical References
Citizenship-based taxation: IRC §61 defines gross income as “all income from whatever source derived.” Residence abroad does not create a statutory exemption from US income tax. The Supreme Court affirmed this principle in Cook v. Tait, 265 U.S. 47 (1924), which remains the foundational authority for US citizenship-based worldwide taxation.
Foreign Earned Income Exclusion: The statutory authority for the FEIE is IRC §911. The exclusion amount is adjusted for inflation annually under IRC §911(b)(2)(D). For 2025, the maximum exclusion is $130,000. Eligibility requires a foreign tax home and qualification under either the bona fide residence test or the physical presence test (330 full days in any consecutive 12-month period).
Anti-double-benefit rule: Foreign taxes on income excluded under the FEIE cannot be credited under Form 1116. The FTC and the FEIE are mutually exclusive on the same income. Taxpayers who partially exclude income may claim the FTC only on the non-excluded portion, using allocation rules under Publication 514.
Foreign Tax Credit: IRC §901 allows a credit for income, war profits, and excess profits taxes paid or accrued to a foreign country. The credit is limited by the ratio of foreign-source income to worldwide income, computed separately for each income category on Form 1116. Unused credits carry back one year and forward ten years within the same income basket.
FBAR: The Bank Secrecy Act, 31 U.S.C. §5314, with implementing regulations at 31 C.F.R. §1010.350, requires US persons to report foreign financial accounts when the aggregate value exceeds $10,000 at any point during the calendar year. The filing is electronic through FinCEN’s BSA E-Filing System; submission with the income tax return does not constitute valid FBAR filing. Non-willful civil penalties are assessed per report (one per year) under Bittner v. United States, 598 U.S. 85 (2023).
Form 8938: IRC §6038D, enacted as part of the Foreign Account Tax Compliance Act (FATCA), Pub. L. 111-147, requires disclosure of specified foreign financial assets when aggregate value exceeds the applicable threshold. The statute of limitations does not begin to run until Form 8938 is filed. For income omissions attributable to undisclosed foreign financial assets exceeding $5,000, the IRS has six years to assess tax.
US–France Treaty savings clause: Article 29(3) of the US–France income tax convention (signed 1994, most recently amended by Protocol in 2009) preserves the US right to tax its citizens as if the convention had not come into effect. US citizens resident in France cannot use the treaty to override the worldwide income rule or eliminate the annual filing obligation.