Moving guide · France → US
Moving from France to the US: what happens to your money (with jokes)
You're swapping the boulangerie for the drive-through, the RER for a car you'll name, and the impots.gouv website for the IRS. Good news: many early retirees pay less tax after the move. Less good news: the forms have acronyms that sound like sneezes. Here's the map.
- France's exit tax only concerns you above €800,000 in shares, and for a move to the US it's put on hold automatically. Keep the shares 2 years (5 above €2.57M) and it's cancelled.
- The year you move, you file in France as a resident until departure day, then as a non-resident; the US taxes you from the day your US residence starts.
- The US doesn't reset your purchase prices: gains built up in France are taxed in the US when you sell.
- Assurance-vie, PEA, PEE and French funds become "PFICs" for the IRS: heavy paperwork, harsh tax. Decide what to keep before you go.
- Your French state pension stays taxed by France only, and the US leaves it alone.
- States matter: Texas or Florida charge no income tax; California goes up to 13.3% and ignores the treaty.
1. The exit tax: scary name, mostly a formality
France's exit tax (article 167 bis of the tax code) taxes the gains on your shares as if you had sold them the day you leave. It only applies if you lived in France at least 6 of the last 10 years and your shares and securities are worth €800,000 or more (or you own 50% of a company). PEA, assurance-vie, real estate and crypto are left out.
The rate is the flat tax, 31.4% since 2026 (12.8% income tax + 18.6% social levies). But for a move to the United States, payment is deferred automatically: the US is on the French tax office's list of eligible countries. You declare the gains on form 2074-ETD, then a short follow-up form each year. If you still hold the shares after 2 years (5 years when they're worth €2.57M or more), the tax is cancelled. Sell before that date and the bill comes due, minus the US tax you paid on the same gain.
Joke break: it's called an exit tax, but if you just sit on your shares for two years it quietly leaves before you do.
2. The year of the move: two countries, one very long spring
In France, the following May you file form 2042 for January 1 to departure day (everything, worldwide), and 2042-NR for French income only after that (rent from your Lyon apartment, say). In the US, you're a resident from the first day you're here with a green card, or once you pass the "183 weighted days" test. The first year is usually "dual-status": half resident, half not. Married couples can choose to be US residents for the whole year and file jointly, which often lowers the bill.
If both countries think you live there on the same days, the treaty's tie-breaker decides: first where your permanent home is, then where your life is centred.
3. No fresh start on what you paid
The US keeps your original purchase price. A share bought in Paris for €20 and worth €100 when you land is taxed in the US on the whole €80 gain when you sell, converted to dollars at each date's rate. The exit tax doesn't change that. Keep your old statements: the IRS will want your 2011 purchase price, and your French bank archived it somewhere between a castle and a cave.
4. Your French savings, seen from the IRS
| You hold | In France after the move | In the US |
|---|---|---|
| Assurance-vie | Withdrawals taxed under non-resident rules | Treated as foreign funds (PFIC), not as life insurance: a Form 8621 each year, harsh tax when you take money out |
| PEA | Can usually stay open; after 5 years, gains are free of French income tax | Just a taxable account, and the funds inside are PFICs |
| PEE, PERCOL | Leaving your job is one of the cases that unlock a PEE early | Employer funds are usually PFICs too |
| French funds and French-listed ETFs | Gains taxed only by the US | PFIC: top tax rate plus an interest charge |
| Shares of single companies (LVMH, Air Liquide…) | France withholds up to 15% on dividends | Normal shares, with a credit for the French withholding |
| Your apartment in Lyon, rented out | Rent taxed at 20% minimum plus 17.2% social levies | Taxed again, with a credit for the French income tax |
| French bank accounts | Nothing changes | FBAR above $10,000 in total; Form 8938 above $50,000 ($100,000 for a couple) |
What many people do: unwind French funds before leaving (the gain is then taxed in France as a resident), think hard about the assurance-vie, and keep single shares and property. Then invest through US-domiciled ETFs.
Joke break: PFIC stands for "passive foreign investment company". It is the least passive thing that will ever happen to your weekends.
5. Pensions: the treaty's nicest surprise
Your French state pension (CNAV and the other basic schemes) stays taxed by France only, and the US leaves it out of your income, even once you're a US resident. That comes from article 18 of the treaty, one of the few rules the US agreed to respect for its own residents. Supplementary pensions (AGIRC-ARRCO) are probably treated the same way; confirm with an accountant. A private pension or a PER is taxed by the US instead. France withholds tax on pensions paid abroad at 0%, 12% or 20% depending on the amount. Quarters worked in both countries add up for each country's pension, thanks to the 1988 social security agreement.
6. Pick your state like you'd pick a cheese
Federal tax is the same everywhere. State tax is not. Alaska, Florida, Nevada, New Hampshire, South Dakota, Tennessee, Texas and Wyoming have no income tax; Washington only taxes large capital gains (7% above $262,000). California goes up to 13.3%, taxes gains like a salary, gives no credit for French tax and doesn't follow the treaty, so it can tax the French pension that the IRS leaves alone. New York goes up to 10.9%, plus up to 3.9% in New York City.
7. Two examples, with real numbers
US federal tax computed with Bordo's 2026 rules; the rest estimated from the rules above, rounded. Your numbers will differ.
Sophie, 52, single, from Paris to Austin, Texas
Savings: €1.1M in a securities account built over 15 years (€450,000 of it is gain) and €80,000 in an assurance-vie. No pension yet.
| Exit tax | In scope (over €800,000): about €141,000 computed, deferred automatically, cancelled in 2 years if she keeps the shares |
| Her yearly income in Texas | About $46,000: dividends, interest and shares she sells |
| US federal tax | $0: below about $66,000 of income, a single person's dividends and long-term gains are taxed at 0% |
| Texas state tax | $0 |
| Watch out | Selling half her French shares in year one would bring about €70,000 of exit tax due, minus the US tax on the same gain. Spend from other money first. |
| Assurance-vie | A PFIC for the IRS: either a Form 8621 every year or a plan to close it, ideally before she moves |
Her biggest new expense: a cowboy hat she swears is "ironic".
The Moreaus, a family of 4, from Lyon to San Diego
Household: Julien, 49, and Claire, 47, French citizens with green cards; Léa is 14 and Hugo 11. Savings: €2.4M: €900,000 securities account (€300,000 of gain), €600,000 assurance-vie, €150,000 PEA, €80,000 PEE, and their Lyon apartment rented for €1,400 a month.
| Exit tax | In scope: about €94,000 computed, deferred automatically, cancelled after 2 years if they keep the shares |
| US federal tax | About $0 on roughly $70,000 of investment income and rent: 0% on gains and dividends at this level, plus the child tax credit |
| California tax | A few hundred dollars this year, because California taxes gains like a salary. At larger sales it climbs toward 9.3% and more. |
| The Lyon apartment | France taxes the rent first (20% minimum plus social levies); the IRS credits the French income tax; California taxes it again with no credit |
| Assurance-vie, PEA, PEE | All PFICs for the IRS. The PEE can be unlocked when Julien leaves his job; the PEA is free of French income tax after 5 years |
| Later: French state pensions | Taxed by France only. The IRS ignores them; California may not |
Léa and Hugo will be bilingual by spring. Julien will still pronounce "Worcestershire" with total confidence and zero accuracy.
8. Before you go: your plan Pro
A move like this needs a plan and a checklist. There is a lot to get right, in the right order: the exit-tax rules to respect, what to do with your assurance-vie, PEA and French funds before you leave, which state to choose, and the French and US forms to file each year. Every household's list is different, so Bordo Pro builds yours: each step with its date, the forms for your situation and a reminder before every deadline.
Bordo turns your savings into a monthly paycheck and computes your US federal tax, free. The exit tax, state tax, French pensions for US residents and the PFIC checks are coming in Bordo Pro.
This guide shares experience and the rules as we understand them in 2026; some points (AGIRC-ARRCO, the yearly list of exit-tax countries) need a professional's confirmation. It is not tax or legal advice. Moving the other way? Read Moving from the US to France.