---
title: "US tax for Americans in France | Expat Tax Abroad"
url: https://expattaxabroad.com/insights/us-tax-americans-in-france/
description: "CSG and CRDS are creditable on a US return, which raises the credit and is worth revisiting on open years — and an assurance-vie is a reporting problem."
lang: en
---

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Filing rules · 22 September 2026

# US tax for Americans in France

There is a US–France income tax treaty and a totalization agreement. Since 2019 the IRS has accepted CSG and CRDS as creditable income taxes rather than social charges, which raises the credit available on Form 1116 — and is worth revisiting on earlier years still within the amendment window. The item that catches people the other way is the assurance-vie.

Image: A treaty and a totalization agreement both in place, with CSG and CRDS marked as creditable income taxes on the US return. (https://expattaxabroad.com/features/art-france-1600.webp)

Image: Jorge I. Rivas, EA (https://expattaxabroad.com/_astro/jorge-rivas-avatar.BkTc9hQv_ZqNxAY.webp)

Jorge I. Rivas, EA

Enrolled Agent · 7 minutes to read

## CSG and CRDS are creditable, and that changed in 2019

For years CSG and CRDS were treated as French social charges and left off Form 1116. Since 2019 the IRS has accepted them as creditable income taxes, which materially raises the credit available against US tax on the same income.

If earlier returns treated them as non-creditable, the credit was understated — and years still within the amendment window can be corrected. It is one of the few genuinely retrospective wins in this field, and it is worth checking before the window closes rather than after.

## The credit generally beats the exclusion

French income tax reaches 45%, and with CSG and CRDS creditable alongside it the total creditable French tax on a professional salary usually exceeds the US tax on the same income. Form 1116 removes the liability and leaves credits carrying forward, while the exclusion leaves French tax unused and the income uncounted for IRA purposes.

## Assurance-vie: favourable there, expensive here

Assurance-vie is tax-favoured in France and is the French product that most often complicates an American return. It is reportable on Form 8938, and the funds held inside it are frequently PFICs — Form 8621, and a default calculation that taxes a disposal at the highest ordinary rate for every year of the holding period, with interest.

A wrapper that simplifies a French tax position can complicate the US one considerably, and the two need to be looked at together before it is opened rather than after it has grown.

## The treaty's relief for US citizens living in France

The treaty contains a mechanism specific to US citizens resident in France: France gives relief for US tax on certain US-source income, which prevents the citizenship-based US claim and the French residence-based claim from colliding. It is one of the more generous arrangements in the US treaty network, and it needs to be claimed correctly on the French side to work.

The French wealth tax on real estate is the other side of the coin: it is not an income tax, so it is not creditable on Form 1116 at all.

## The totalization agreement covers the social security half

French social security sits inside the totalization agreement, so a self-employed American contributing in France generally escapes the 15.3% US self-employment charge — evidenced by a certificate of coverage. That is separate from the CSG and CRDS question, which is about the income tax credit.

## A worked example, tax year 2025

A single American employed in Paris on salary equivalent to $140,000, with French income tax plus CSG and CRDS totalling $46,000 for the year.

| Salary | $140,000 |
| --- | --- |
| French income tax, CSG and CRDS paid | $46,000 |
| US taxable income after the standard deduction | $124,250 |
| US income tax before the credit | $22,667 |
| Foreign tax credit allowed | $22,667 |
| US income tax after the credit | $0 |
| Excess credit carried forward | $23,333 |

Creditable French taxes of $46,000 exceed the $22,667 of US tax on the same income, so the credit removes the liability and $23,333 carries forward. Treating CSG and CRDS as non-creditable social charges — the position before 2019 — would have cut the credit claimed and, on a year with more US tax than this, produced a bill. Sources: IRC §901 and §904; IRS Form 1116 instructions; Rev. Proc. 2025-32.

Scroll the table sideways

| Fact | Position |
| --- | --- |
| US income tax treaty | Yes |
| Totalization agreement | Yes |
| Local income tax | Progressive to 45%, plus CSG and CRDS |
| Self-employment tax (SECA) | Relieved where the agreement covers you |
| FBAR threshold | $10,000 aggregate, any point in the year |

Sources

IRC §901, §904 and §911; US–France income tax treaty, including the relief article for US citizens resident in France; US–France totalization agreement; the 2019 change in the US position on CSG and CRDS; IRS Publication 54; IRS Publication 514; IRS Form 8938 and Form 8621 instructions; Rev. Proc. 2025-32; 31 CFR 1010.350. US figures are tax year 2025. Checked 22 September 2026.

Change log

22 September 2026 First published

France — full country guide →: https://expattaxabroad.com/countries/france/
Expat tax returns →: https://expattaxabroad.com/services/expat-tax-returns/
FBAR / FATCA compliance →: https://expattaxabroad.com/services/fbar-fatca-compliance/
Treaty & totalization matrix →: https://expattaxabroad.com/tools/treaty-totalization-matrix/
Streamlined catch-up filing →: https://expattaxabroad.com/services/streamlined-catch-up-filing/
Home →: https://expattaxabroad.com/
All insights →: https://expattaxabroad.com/insights/

## Questions Americans in France ask

### Can I credit CSG and CRDS on my US return?

Yes. Since 2019 the IRS has accepted them as creditable income taxes. If earlier returns treated them otherwise, amending years still open is worth examining — the credit was understated in those years.

### How is my assurance-vie taxed in the US?

Not the way it is taxed in France. It is reportable on Form 8938, and the funds inside it are frequently PFICs, so the US treatment is usually less favourable than the French one.

### Is the French wealth tax on property creditable?

No. It is a wealth tax rather than an income tax, so it does not go on Form 1116. Only income taxes — which since 2019 includes CSG and CRDS — support a foreign tax credit.

### Does the treaty stop France and the US both taxing me?

It manages the overlap rather than removing it. There is a mechanism specific to US citizens resident in France under which France gives relief for US tax on certain US-source income, and it has to be claimed correctly on the French side to work.

### I have not filed for several years while in France. What now?

If the failure was non-willful — which describes most people in this position — the Streamlined Foreign Offshore Procedures waive the failure-to-file, failure-to-pay and FBAR penalties: three years of returns, six years of FBARs, and Form 14653.

## Filing from France?

Fifteen minutes settles whether CSG and CRDS were credited on your open years, and what your assurance-vie needs on the return.

Book a 15-minute call: https://expattaxabroad.com/book/

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