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.
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.
Scroll the table sideways
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.
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?
Twenty minutes settles whether CSG and CRDS were credited on your open years, and what your assurance-vie needs on the return.