Wealth Management for Americans Moving to France: The 2026 Money Map

When you move to France, your money is governed by two sets of rules at once: US tax law, which follows you because of your citizenship, and French law, which applies because you now live here. They were not written to fit together, and the gaps between them are where Americans lose money. This guide covers the five places that happens most often: your US bank and brokerage accounts, your retirement accounts, how you invest once you are resident, the French wealth tax on real estate, and inheritance. Each section sets out what changes, what to decide before you leave, and where the detailed guide sits. Almost all of it is cheaper to arrange from the US side than to unwind from France. This article is for informational purposes only and is not tax or legal advice; consult a qualified cross-border tax professional before making any filing decision.

The financial trap most Americans do not see coming

The day a French address posts to your US brokerage, the firm can block new purchases or ask you to move the account. The European funds a French bank would offer you instead are PFICs, which the IRS can tax at up to 37% plus an interest charge. The two happen together and to the same people: US platforms restrict non-resident accounts, while EU rules (MiFID II and the PRIIPs regime) bar residents from buying US-domiciled ETFs and mutual funds. That leaves you between a US system closing the door behind you and a French system whose standard products carry a punitive US tax.

None of this is a reason to stay home. It is a reason to sequence the move. Almost every fix here is cheaper and simpler to make from the US side, before you become a French tax resident, than to unwind once you have landed. The rest of this guide walks each piece in the order it will actually reach you.

Your US financial life, translated into French-resident terms

Most of your US accounts can stay open, US-source retirement and investment income is largely shielded by the treaty, and the real trouble clusters around two things: pooled European funds and French real estate above €1.3 million. Use this map to see where each asset stands before you read the section that applies to you.

The pattern is worth holding onto: keeping US-domiciled assets is usually the safe path, and importing French-style pooled products is usually the expensive one.

What actually changes when you become a French tax resident

You become a French tax resident under Article 4B of the tax code the moment France is your main home, and from that day you declare your worldwide income there, US salary, pensions, dividends and all. That sounds alarming to Americans who already file in the US. In practice the treaty does most of the heavy lifting, and the surprises are narrow but real.

Under Article 18 of the US-France treaty, your US Social Security and private pension income, including 401(k) and IRA distributions, are taxable only in the United States. Under Article 24, US-source dividends and capital gains are handed a French tax credit that usually cancels the French tax entirely for US citizens. You still report every dollar in France, and that reported income can push your other French-taxable income into a higher band through the effective-rate calculation.

The gap the treaty does not close is social charges. CSG and CRDS run at 17.2% and are not income taxes covered by the treaty, so they can apply to some income and are not creditable against US tax. Getting these positions right on your first return is exactly the kind of thing a first-year tax orientation exists for, and the mechanics are laid out in our guides to filing your first French tax return and US tax filing from France, FBAR, FATCA and the treaty.

Your US bank and brokerage accounts: keep, close, or move

Nothing obliges you to close a US bank account when you move. Your brokerage is another matter. Some firms restrict or freeze accounts once you hold a non-US address, others quietly keep them running, and a few will let you trade but not buy new funds. The safest route is to confirm your provider's non-resident policy before you leave, keep a reliable US mailing address, and consider moving to a custodian that openly serves Americans abroad.

Keeping the account open matters more than it looks, because it is what lets you hold US-domiciled index funds and individual stocks, the very assets that keep you out of the PFIC regime. Closing the account and reinvesting from France is how people fall into the trap in the first place.

Keeping a US brokerage running as a French resident often means moving to a firm built for Americans in Europe. Our independent partner EuroAmerican Financial Advisors is licensed in both the European Union and the United States, which is what allows it to advise you as a resident of France and to hold US-domiciled investments on your behalf. EuroAmerican Financial Advisors is an independent partner and EasyFranceNow does not provide financial advice.

Two deep-dives carry the detail here: preparing your US finances before you leave and what happens to a Fidelity or Schwab account in France.

Your 401(k), IRA and Roth after the move

Your US retirement accounts stay in the US and, under Article 18, their distributions are taxable only in the United States, with France granting a credit so there is no second French income tax on the same money. That is one of the genuine advantages of the treaty for American retirees, and it means you do not need to move or unwind these accounts to protect them.

The Roth is the unsettled corner. The treaty appears to preserve the tax-free character of qualified Roth distributions, and the US Treasury's technical explanation treats Roths as covered plans. French administrative practice, though, has been inconsistent, and cross-border advisers disagree on how a given French tax office will handle Roth growth. Treat it as an open question to confirm for your own file, not a settled rule. The full treatment, including the French reporting form for the account, is in our guide to how your 401(k) and IRA are treated in France.

Investing as an American in France: the PFIC trap

A European mutual fund, ETF, or assurance-vie fund is almost always a passive foreign investment company, and under the default section 1291 rules the IRS can tax gains and certain distributions at the highest ordinary rate, 37% for recent years, spread back across your holding period with an interest charge on top. The effective rate routinely lands north of 40%. On top of the tax, you owe a separate Form 8621 for every PFIC, every year.

What the trap does to a normal portfolio

The difficulty is that these are the products a French bank will recommend first, because assurance-vie is genuinely tax-efficient for a French national. For a US person, the same contract creates a US tax bill and an annual filing obligation. A mark-to-market or QEF election can soften the treatment, but both need a timely election and cooperation from the fund, and neither is available on most retail European products.

Where you can actually put your money

The clean holdings are US-domiciled funds and individual securities in a US account, which sidestep the PFIC rules entirely and keep you in the treaty lane that shields US investment income from French tax. Access is the catch: once you live in France, EU rules bar the sale of US-domiciled funds to retail investors, so buying them means going through a cross-border adviser licensed in both the EU and the US who can transact on your behalf, or building the portfolio from individual stocks and bonds, which are not restricted. The whole decision, including the brokerage-access problem, is mapped in our guide to investing as an American in France.

If your money is already sitting in European funds, or a French adviser is steering you toward assurance-vie, this is the point where a plan saves you the most. A 30-minute consulting call with Maxime turns your PFIC exposure and clean-up into a written plan within 48 hours, for $199, so you fix it before the next Form 8621 comes due.

The French wealth tax (IFI) and the five-year window

France's wealth tax reaches real estate only, and only above €1.3 million of net taxable property, with the tax computed from €800,000 upward on a scale that runs from 0.5% to 1.5%. Financial assets, retirement accounts and portfolios are outside it entirely. Your main home gets a 30% abatement on its value.

What the IFI does and does not tax

The IFI is not a tax on your net worth, which is the point most Americans get backwards. A retiree with two million dollars in a US brokerage, a full 401(k) and a modest French apartment may owe nothing, because only the apartment counts and it sits under the threshold. The tax bites when French property, or your share of real estate held through companies, crosses €1.3 million.

The five-year grace period new residents miss

This is the provision worth the most money to a new arrival. Under CGI article 964, someone who becomes French-resident after at least five years of not being French tax-resident is taxed on French real estate only, until 31 December of the fifth year after arrival. Your US home and any other foreign property stay outside the IFI for that window. Structuring foreign real estate before you arrive, not after, is what preserves it. The full mechanics, and how the 2026 budget left the IFI unchanged, are in our guide to the IFI and its five-year grace period, and the tax case for a Monaco base sits in the Monaco comparison.

Inheritance and succession

French succession law reserves a fixed share of your estate for your children whatever your will says, one-half with one child, two-thirds with two, three-quarters with three or more, under Code civil article 913. This forced heirship is the single biggest shock for American families used to leaving assets as they choose.

Brussels IV, and why it no longer gets you out of forced heirship

This is the point most often reported wrongly. The EU Succession Regulation, known as Brussels IV, does let you elect the law of your nationality, US state law, to govern how your estate is distributed. Since a French law of August 2021 added a third paragraph to Code civil article 913, however, that election no longer produces the result Americans expect. Where the foreign law you chose provides no reserved share, children who are EU nationals or EU residents can claim compensation out of assets located in France, up to the share French law would have given them. For a French resident with children, treat forced heirship as unavoidable in practice rather than as something a US will can switch off.

The workable approach is not to fight the reserved share but to plan around it: mirroring wills in every country where you hold assets, each one valid locally and all of them drafted together so the set produces a single coherent outcome under the French rules. That is a job for a notaire and a US estate lawyer working jointly, not for either one alone.

What the tax actually is

French succession tax runs on a separate track. Between parents and children there is a €100,000 abatement per parent per child, then a progressive scale from 5% to 45%. A surviving spouse or PACS partner pays no succession tax at all. The US-France estate and gift tax treaty coordinates the two systems, generally taxing real estate where it sits and financial assets where the owner is domiciled, with credits to prevent double taxation. The full picture, including where an SCI helps and where it does not, is in our guide to French inheritance law for Americans.

French banking basics and FATCA refusals

Some French banks decline American clients outright, citing the cost of FATCA reporting, and this is a documented friction rather than a rumor. It is also solvable. You hold the droit au compte: if you are refused, the Banque de France can designate a bank that must open a basic account for you. Several banks accept Americans as a matter of routine, and knowing which ones saves weeks.

Opening the account is one job; using it well is another. The banking unblocker is the done-for-you version when a refusal is holding up your move, and the two guides that carry the detail are which French banks accept Americans and the Livret A and other French savings for expats. One caution on the Livret A: its interest is tax-free in France, but the IRS still taxes it and the account is reportable on your FBAR once your foreign balances top $10,000.

Moving money across the Atlantic

A euro-dollar move of even 10% on a large transfer changes six figures on a million-dollar move, which is why the method and timing of a transfer matter as much as the rate on any given day. Banks tend to give the worst exchange rates and bury the cost in the spread; specialist transfer services usually beat them, sometimes by a wide margin, on both the rate and the fee.

The practical points are simple. Move money in tranches rather than all at once if you can, so a single bad day does not set your whole budget. Keep enough in dollars to cover US obligations you are keeping. And time any large, discretionary transfer around when you actually need the euros, not around a rate you are hoping for.

The regulated-advice layer: when you need a cross-border wealth manager

There is a clean line between operational help and regulated financial advice, and knowing which you need keeps you out of trouble. EasyFranceNow handles the procedural sequence of a move; we do not give investment or tax advice, and we do not manage money. Once the question becomes how to invest, how to draw down retirement accounts across two tax systems, or how to restructure a portfolio before you land, that is regulated advice, and it belongs with a firm licensed to give it.

For an American in France, the specific thing to look for is a firm licensed on both sides: authorised in the EU, which is what allows it to advise you as a French resident, and registered in the United States, which is what allows it to work with your US accounts and US-domiciled investments. A US-only adviser will not see the IFI or the French return, and is not licensed to advise you once you live here; a French-only adviser will walk you straight into PFICs. Firms holding both sets of permissions are rare, and that is exactly what you are looking for.

This is where our independent partner EuroAmerican Financial Advisors fits: a cross-border firm whose advisers are licensed in both the European Union and the United States, working with Americans building a life in France. EuroAmerican Financial Advisors is an independent partner and EasyFranceNow does not provide financial advice.

The mistakes that cost the most, and why they happen

The expensive errors are rarely exotic. They come from applying US instincts to French rules, or French advice to a US taxpayer.

Selling US funds after you become resident is a common one. Gains realized once you are French-resident fall under French capital-gains rules even on US-source assets, though the treaty credit often offsets the French side; people who rebalance without checking their residency date get surprised. Buying assurance-vie on a French banker's recommendation is another. It is the standard French savings product, and for a US person the funds inside it are usually PFICs, so the friendliest advice in the room becomes an IRS liability.

Then there is the assumption that closing US accounts ends US filing. It does not. You still file, and foreign accounts over $10,000 still trigger the FBAR. Finally, plenty of new residents assume the IFI five-year window and the Roth's tax-free status take care of themselves. Neither does. The window has to be set up before arrival, and the Roth's French treatment has to be confirmed for your own situation, because practitioners genuinely disagree.

Your first three financial moves before you go

The single most valuable step is a cross-border tax review before you establish French residency, because the IFI five-year window, PFIC clean-up and estate documents are all cheaper to set up from the US side than to unwind from France.

You can handle parts of this alone. Opening a French account, filing your own FBAR once balances top $10,000, and keeping your US bank running are all manageable without help. What you should not improvise is the PFIC and IFI timing, the treaty positions on your first French return, and the set of wills that has to hold together under the French reserved-share rules, where one wrong order can cost years of tax.

If you want that sequence handled in order rather than guessed at, a consulting call turns it into a written plan within 48 hours for $199, and the Navigator maps the cost and timeline of the wider move, from visa to residency.

FAQ

Can I keep my Fidelity or Schwab account after moving to France?

Often yes, but it depends on the firm. Some US brokers restrict or freeze accounts once you hold a non-US address, others keep them running, and a few let you hold but not buy. Confirm your provider's non-resident policy before you leave, and consider a custodian built for Americans abroad. Details: our guide on Fidelity and Schwab accounts in France.

Do I owe French wealth tax on my US home?

No, not while you own no French real estate above the threshold. The IFI taxes real estate over €1.3 million net, and under CGI article 964 new residents are taxed on French property alone until 31 December of the fifth year after they move. Your US home stays outside the IFI during that window.

Are my 401(k) and IRA taxed twice?

No. Under Article 18 of the US-France treaty, 401(k) and IRA distributions are taxable only in the United States, and France grants a credit so there is no second French income tax on the same money. You still report the distributions on your French return, where they feed the effective-rate calculation on your other French income.

Will a French bank refuse me because I am American?

Some do, citing the cost of FATCA reporting. It is solvable: you hold the droit au compte, so if you are refused the Banque de France can designate a bank that must open a basic account. Several banks accept Americans routinely. Our guide covers which French banks say yes.

What happens if I buy European index funds in France?

They are almost always PFICs. Under the default rules the IRS can tax gains and certain distributions at up to 37% for prior years, plus an interest charge, with a Form 8621 due per fund every year, per the IRS Instructions for Form 8621. Hold US-domiciled funds or individual securities instead.