French taxes on US investments for dual US/French nationals

Hi, I have the French/US citizenship, living in US for the past 18 years and looking at moving back to France (and be a resident).

I understand that 401k/IRA (as well as US social security) will not be taxed in France. However I could not find a definitive answer about standard US investments for dual citizens.

For US citizens living in France, my understanding is that effectively no taxes are paid in France on US investments (for dividends/proceeds of sale) because the Fisc gives back a credit on the income tax paid on these.

However, I have the dual US/French nationality. So the question is:

  • Can I still take advantage of the credit above ?
  • I hear that because I’m also French, I might still have to pay the CSG/CRDS and wouldn’t get a credit for these. Is that correct ?

Thanks.

Hello Nicolas and welcome to the forum


I am sure someone will chime in
 but maybe not tonight
 it’s heading towards midnight here
 :thinking:

Hold on, you want free tax advice :roll_eyes: What will you do if it’s wrong and you get hit with penalties and interest? Go talk to an expert is my advice.

The France / US tax treaty is here https://www.irs.gov/pub/irs-trty/france.pdf

Taxes in France don’t vary according to a person’s nationality. All residents are subject to the same tax laws, and the same international tax treaties where applicable. CSG/CRDS is charged on certain types of income and there are certain exemptions. Nationality, and whether you are French only or dual French or not French at all, doesn’t come into it. AFAIK.

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@nicolas

Here are some other interesting sites to work you way through
 there will be bits that apply to your situation
 . in there
 somewhere
 I expect


and

https://www.diplomatie.gouv.fr/fr/services-aux-citoyens/preparer-son-expatriation/dossiers-pays-de-l-expatriation/etats-unis/fiscalite/article/convention-fiscale-113153

From whom have you heard this ???

Have you actually contacted the French Tax people yet
 to ask them about your situation ???

Thank you for the answers.
John, to be clear: I will talk to an expert comptable before making any decision. But it is particularly difficult to find one who is knowledgeable in this domain, in particular when there is a 9 hours time difference

Stella, I haven’t contacted the Fisc about this, it didn’t come to mind. For some reason, I assumed I would end up in a kafkaeske phone rabbit hole with them. But maybe not. I’ll look into that.

Based on the links you provided, it looks like it doesn’t matter if I have the dual citizenship or not. It only matters if I’m a US citizen and pay taxes in the US and can prove it. And it seems to includes all types of taxes.

Hi Nicolas - you could also try contacting the French Embassy in DC as an immediate ‘fix’ - they have a dedicated taxation attachĂ©.

France in the US - Tax Attaché

Hi Nicolas

Please could you visit your Registration page, click on “preferences” and upload a photo


This is a friendly, helpful forum
 and photos are so much nicer than the somewhat bleak “letter”


cheers