Last Updated: April 2026
France's departure tax regime is one of the most comprehensive in Europe — it captures not just private company shareholders (like Germany's Wegzugsteuer) but also portfolio investors with large unrealised gains in securities accounts. The impôt de sortie (exit tax), significantly broadened by reforms in 2011 and updated in subsequent Finance Laws, affects both departing French citizens and long-term residents with substantial investment portfolios. Beyond the exit tax, France's notorious administrative complexity means departing residents must navigate the déclaration de départ process, assurance-vie rules, CSG/CRDS on French-source income, and Caisse de retraite pension management — all while coordinating with the fiscal calendar of the destination country.
France-to-USA migration is common among professionals in finance, technology, academia, and the arts — particularly Paris to New York or San Francisco. Key planning points:
Exit tax and US first-year residency: The French impôt de sortie is calculated on the day before departure from France. If you become a US resident later (e.g., you depart France in March and arrive in the USA in May), the exit tax gain is NOT US-taxable — you were not a US resident when the deemed disposal occurred. Ensure your tax advisor understands this timing. If you depart France and immediately become US-resident (same day), you need careful analysis of which country's rules apply first.
Assurance-vie US reporting: French assurance-vie contracts must be reported to the IRS. The correct treatment is complex — it may be a foreign grantor trust or a foreign insurance policy. Consult a US tax attorney before deciding whether to liquidate the assurance-vie before US residency begins.
France-USA DTA complexity: The France-USA double taxation agreement is among the most complex DTAs in the world. It has a saving clause, multiple protocol amendments, and specific rules for pensions (Article 18), dividends (Article 10), and business income. US residents receiving French dividends face a 5% or 15% French withholding depending on ownership level, claimable as FTC on the US return.
French social security: Moving to the USA on an L-1 or H-1B visa: check the France-USA totalization agreement. French social security contributions may continue to be required for a transitional period; the totalization agreement prevents double contribution. Contact CLEISS (the French liaison office for social security) for guidance.
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Get US Expat Tax Help After Leaving France →Potentially yes. The impôt de sortie thresholds for 2025: either (a) total securities portfolio FMV > €1,300,000 or (b) unrealised gains in the portfolio > €800,602. If your €1.5M portfolio exceeds the €1,300,000 total value threshold, and you have been French tax resident for at least 6 of the last 10 years, then YES — the exit tax applies. All unrealised gains (FMV minus your original purchase cost) are deemed realised on departure day and taxed at 30% PFU. Because the USA is not in the EU/EEA, there is no automatic deferral — the tax is due within 90 days of departure, unless you arrange a surety (caution). To manage cash flow, you can: (1) request payment by instalments (maximum 5 years); (2) provide a bank guarantee to the French tax authority; or (3) sell some securities before departure to fund the tax payment. Important: losses in your portfolio can offset gains — a net gain calculation is used. This can significantly reduce the exit tax if you have some unrealised losses in the portfolio.
No. French real estate (immobilier) is NOT included in the impôt de sortie calculation. The exit tax applies to securities (financial assets), not physical real estate. However, this does not mean you owe no French tax on your property as a non-resident. When you eventually sell a French property as a non-resident: the gain is taxed at 19% income tax + 17.2% CSG/CRDS (for non-EEA, non-treaty-protected non-residents) = 36.2%. For treaty-protected non-residents (e.g., under France-USA DTA), CSG/CRDS may still apply even if income tax is credited in the US. Additionally, France has a non-resident capital gains tax on real property managed via the notaire at sale — a notaire will apply the tax at source. You also need a représentant fiscal (French fiscal representative) if you are non-resident and selling French real estate — mandatory for non-EEA residents.
Form 2074-ETD (Declaration of Unrealised Capital Gains, Claims, and Instalments on Departure) must be filed along with your final French income tax return for the year of departure. Deadline: same as your final French income tax return — typically online in May/June of the following year, with the balance due in September. For EU/EEA departures: file 2074-ETD to declare the unrealised gains AND to elect the automatic deferral (sursis de paiement) — the tax is logged but not collected immediately. For non-EU departures: file 2074-ETD to declare gains and either pay immediately or request instalment/surety arrangements with the Recette des non-résidents (DINR — Direction des Impôts des Non-Résidents). Missing this form or filing late: the exit tax may be assessed with penalties and interest. The DINR (based in Paris) handles all non-resident French tax matters and is the point of contact for exit tax compliance.
BSPCEs (Bons de Souscription de Parts de Créateur d'Entreprise) and stock-options at the departure date: the exit tax under Article 167 bis applies to shares already held at departure. Unexercised options are NOT shares — they are not subject to the exit tax at departure. However, when you exercise BSPCEs or stock options after departure as a non-resident, the gain (the difference between exercise price and FMV at exercise) may be subject to French tax depending on the type of plan and when the options were granted. RSUs (actions gratuites) that have already vested and converted to shares before departure: counted in your exit tax portfolio. RSUs not yet vested: the gain on future vesting is a French-source employment benefit — potentially subject to French withholding even after departure, depending on the French service fraction. Complex area — take advice before departure if you have significant unvested equity.
No — you can maintain French bank accounts as a non-resident. Notify your bank of your change of tax residency. French banks (BNP Paribas, Société Générale, Crédit Agricole, La Banque Postale) all serve non-resident customers, though some accounts may be reclassified or restricted. Non-resident account: your bank must apply the non-resident withholding rates on interest income. Under the FATCA framework, if you become a US resident, your French bank must report your accounts to the IRS annually. FBAR: French accounts exceeding $10,000 must be reported via FinCEN 114. Livret A, Livret de Développement Durable (LDD): these state-regulated savings accounts must be closed when you become non-resident (they are only open to French residents). The accrued interest is tax-free in France up to closure. PEA (Plan d'Épargne en Actions): must be closed within 2 months of becoming non-resident, or converted — losses in the PEA cannot be carried forward after closure.