Furnished studio
Taxable income6 000 €
Tax at 20%1 200 €
CSG and CRDS666 €
Solidarity levy450 €
Total in France2 316 €
€1,866 is then credited against the federal tax linked to this income, up to the amount of that tax.
Calculate my tax →
FREN
France tax treaty United States : your property in France
Do you live in the United States and own a property in France, or want to buy one? Who taxes you, how much, and what you must declare on each side.
United StatesRules up to date as of 2 November 2026Written by Frédéric Moreau, founder of ImmoPourExpatOfficial sourcesThe essentials
- France taxes your rents and your capital gain first, because the property is located there: a 20% minimum tax on rents, 19% on the capital gain, plus 17.2% social contributions (18.6% for furnished rentals).
- The United States also taxes this income, then grants a credit for French tax, up to the amount of US tax.
- The United States is not part of the EEA: the reduced 7.5% rate does not apply.
- IFI remains due in France above €1.3m of net French property assets.
20 %minimum tax on your rents in France, 30% above €29,579 of net income
19 %tax on capital gain in France, before the social contributions
17,2 %social contributions, and 18.6% for furnished rental
1,3 M€of net French property wealth: the threshold of the IFI
Who taxes what ?
France taxes your rents and your capital gain first. The United States taxes them too, then grants a credit for the French tax.
Your rents are taxed on both sides
- France taxes first, because the property is located there
- The United States also taxes your worldwide income
- The French tax becomes a US tax credit, up to the amount of US tax on this income
Minimum tax in France20 %
Social contributions17,2 % or 18.6%
In the United StatesTax credit
The capital gain is paid in France, then declared in the United States
- 19% tax and 17.2% social contributions in France
- Tax exemption after 22 years, social contributions exemption after 30 years
- The gain is recalculated in dollars in the United States, with a credit for the French tax
Tax in France19 %
Social contributions17,2 %
Rate in the United States0, 15 or 20%
17.2%, without the reduced European rate
- The United States is not part of the EEA: no 7.5% rate
- The CSG and CRDS qualify for the tax credit since 2019
- The solidarity levy is not confirmed: have it validated by your CPA
Unfurnished rental17,2 %
Furnished rental18,6 %
Capital gain17,2 %
The IFI remains due in France
- Above €1.3M net on 1 January
- Only your French property is included in the calculation
- The IFI paid gives no right to any US credit
Net wealth threshold1,3 M€
Property outside FranceExcluded
US creditNone
A dedicated treaty for inheritances
- Your French property is taxed in France
- The United States grants a credit for French duties
- New York, Massachusetts and other states have their own tax, with much lower thresholds
2026 federal exemption15 M$
French propertyTaxed in France
US creditArticle 12
Two possible exemptions on resale
- Former main residence sold by 31 December of the year following your departure at the latest
- €150,000 of net capital gain for a French person living in the United States, subject to conditions
- Without European nationality, a US citizen is in principle not entitled to it
Exempt for a French non-resident150 000 €
Tax representativeAbove €150,000 of price
Main residence, US sideUp to $250,000 excluded
How much you pay in France
Three worked cases for a US resident, on 2025 income. The US amount depends on your bracket.
Unfurnished apartment let
Taxable income6 300 €
Tax at 20%1 260 €
CSG and CRDS611,10 €
Solidarity levy472,50 €
Total in France2 343,60 €
€1,871.10 is then credited against the federal tax linked to this income, up to the amount of that tax.
Calculate my tax →Resale after 10 years
Gross capital gain43 750 €
Tax at 19%5 818,75 €
CSG and CRDS3 893,64 €
Solidarity levy3 010,55 €
Total in France12 722,94 €
€9,712.39 is then credited against the federal tax linked to this gain, up to the amount of that tax. Tax representative compulsory.
Calculate my capital gain →The 3.8% NIIT remains due above $200,000 of income, or $250,000 for a couple. The tax credit does not reduce it.
Your formalities, on both sides
A property in France creates obligations in both countries, even with no additional tax to pay.
In France
Property taxDue every year from the owner on 1 January.
Housing taxDue on a furnished property that you keep for your own stays or let short-term.
Occupancy declarationIn “Gérer mes biens immobiliers” on impots.gouv.fr, to be redone if anything changes.
CFE and SIRETFor furnished rental: a SIRET number and the business property contribution.
Income tax returnForm 2042, with the non-residents’ tax office.
Bank accountFATCA: some banks refuse or restrict US persons. Plan for this step early.
In the United States
Form 1040With Schedule E for the rents and Form 1116 for the tax credit.
FBARIf your accounts outside the United States exceed $10,000 at any time in the year.
Form 8938Foreign financial assets. A directly held building is not included, SCI shares are.
SCI: 8865 or 8858In principle a partnership, or a disregarded entity if you are the sole partner.
Form 3520Inheritance or gift from abroad above $100,000.
Your State taxesReturn for your State of residence, under its own rules.
Penalties for failure to file are heavy: have the list drawn up by a CPA used to overseas property.
They live in the United States and have invested in France
Lives in the United StatesJulien, Cannes
36 m² 2-room flat as a short-term rental
★★★★★ on Trustpilot“Thanks to Fred and his team we managed to find a super profitable property and to get a loan offer in 3 months with really attractive terms.”
See their project →Lives in the United StatesJean-Rémi, Gaillac
Building with 4 units and 3 garages in the very centre
▶ In his video“There’s work to do, but I think the work always ends up paying off. So go for it, it’s a great support programme, and beyond that, we’re also building a community.”
See their project →The 8 questions to ask yourself
A clear answer and an example for each topic.
Who taxes your rents?
Both countriesYou declare your rents first in France, where the property is located. You also declare them in the United States, which taxes your worldwide income. To avoid paying twice, the French tax becomes a credit against the US tax linked to these rents.
ExampleA furnished studio let at €12,000 a year: €2,316 to pay in France, of which €1,866 is then credited against federal tax, up to the amount of US tax.
Who taxes your capital gain ?
Both countriesYou pay in France on sale: 19% tax and 17.2% social contributions, with allowances depending on the length of ownership. The gain is then recalculated in dollars in the United States, with the same tax credit.
ExamplePurchase at €250,000, resale at €350,000 after 10 years: €12,722.94 to pay in France, of which €9,712.39 is then credited against federal tax, up to the amount of US tax.
What is the NIIT?
3.8% on topA US tax on investment income, such as rents and capital gains. It applies above $200,000 of income, or $250,000 for a couple filing jointly. Since a ruling of 31 August 2026, the French tax credit cannot reduce it.
ExampleOn $10,000 of net rents, that means $380 more to pay if your income is well above the threshold.
Must you pay the IFI?
Above €1.3MThe IFI looks only at your French property, at its net value on 1 January. Property located outside France does not count. It is paid in France, with no US credit against it.
ExampleAn apartment worth €1.5M with €400,000 of purchase loan remaining: €1.1M net, you are not affected.
Who taxes the inheritance?
France firstYour French property is taxed in France, under the 1978 treaty. If a US estate tax is due, the United States grants a credit for the French duties.
ExampleWith a federal exemption of $15M in 2026, most estates pay only the French duties. Beware of New York and Massachusetts, whose thresholds are much lower.
Which social contributions?
17.2% or 18.6%The United States is outside the EEA: the reduced 7.5% rate does not apply. The CSG and CRDS qualify for the US tax credit since 2019. The solidarity levy is not confirmed: have it validated by your CPA.
ExampleFor the furnished studio: €666 of CSG and CRDS that are credited, and €450 of solidarity levy to be validated.
Do you need a tax representative?
Above €150,000It is compulsory when the sale price exceeds €150,000. The threshold is counted per seller, and a married couple counts as one. None is needed if the capital gain is fully exempt.
ExampleA resale at €350,000 after 10 years requires a representative. After 30 years of ownership, no longer needed.
Does an SCI change the tax?
Not in FranceThe SCI does not change your French taxation. In the United States, it is in principle a partnership (Form 8865), or a disregarded entity if you are the sole partner (Form 8858).
ExampleAn SARL or SAS would be heavier: Form 5471 and PFIC risk. To be validated with a US tax adviser before buying.
The official texts
Frequently asked questions
I am a US citizen and I live in France or elsewhere: does the United States still tax me?
Yes. The saving clause (article 29 § 2) allows the United States to tax its citizens as if the treaty did not exist. Article 24 then provides for the tax credit.
Do the CSG and CRDS qualify for the US tax credit?
Yes. Since 2019, the IRS accepts that they fall outside the France-US social security agreement and no longer contests their use as a foreign tax credit. They are added to the French income tax in the calculation on Form 1116. The 7.5% solidarity levy is not covered by this position: have its treatment validated by your CPA.
Can I credit the French tax against the 3.8% NIIT?
No, according to the Christensen v. United States ruling of the Federal Circuit Court of Appeals (31 August 2026). A possible appeal to the Supreme Court remains to be watched.
Do I have to pay the IFI while living in the United States?
Yes, if your French property is worth more than €1.3M net on 1 January. The treaty leaves this right to France (article 23).
How are my heirs taxed on the French apartment?
France taxes the apartment (article 5 of the 1978 treaty). If a US estate tax is due, the United States grants a credit for the French duties (article 12). With a federal exemption of $15M in 2026, most estates pay only the French duties, apart from the estate tax of certain states (New York, Massachusetts...) whose thresholds are much lower.
Is a French SCI a good idea for a US resident?
The SCI does not change taxation in France (article 13 § 2 a). On the US side, it is in principle a partnership (Form 8865) or a disregarded entity (Form 8858), with additional annual filings. A limited liability company (SARL, SAS) would in principle be a corporation (Form 5471), with a PFIC risk. Have this point validated by a US tax adviser before buying.
I lived in this apartment before leaving for the United States. Is that an advantage on resale?
Yes, on both sides, subject to conditions. In France, a former main residence sold by 31 December of the year following departure at the latest is exempt; the United States meets the tax collection assistance condition (article 28). In the United States, IRC § 121 excludes up to $250,000 of gain ($500,000 for a couple) if the property was your main residence for at least 2 of the last 5 years.
You live elsewhere ?
Switzerland
Luxembourg
Belgium
United Kingdom
Dubai
Canada
Singapore
Spain
Germany
Netherlands
Australia
Italy
Portugal
Ireland
Mexico
Sweden
Poland
Denmark
Norway
Austria
Czechia
Greece
Romania
Serbia
Brazil
Chile
Colombia
New Zealand
Japan
South Korea
China
Hong Kong
Taiwan
Malaysia
Thailand
Indonesia
Vietnam
Saudi Arabia
Qatar
Turkey
MoroccoRules up to date as of 2 November 2026, drawn from the text of the treaty published on impots.gouv.fr and from the BOFiP. This page provides information on the general rules: it does not replace tax advice on your situation.
Let’s talk about your project
You live in the United States and want to invest in France: a conversation to see how we can support you.
Talk to an expertThe information on this page is general and does not replace tax, legal or financial advice suited to your situation.
Investing from abroad has never been so simple
ImmoPourExpat supports expats and non-residents from A to Z who want to invest in property in France: financing, property search, renovation works, taxation and remote management.
TrustpilotTrustScore 4,8 | 276 reviews+1 000 expats and non-residents supported
The ImmoPourExpat offer
The ImmoPourExpat methodFinancingProperty searchRemote renovation worksTaxationRemote managementWhere to invest in FranceInvesting from abroadHouse shareShort-term rentalApartment buildingBuy-to-sellTurnkeyUseful resources
BlogGuides and calculatorsTax treaties2026 bank rankingVideosBarometerGlossaryFAQOur resultsWall of successClient testimonialsThe newsletter
Subscribe to our newsletter, the latest in property investment for expats and non-residents
By subscribing, you accept our privacy policy
Follow us
© 2026 ImmoPourExpat. All rights reserved
Free guide
I have a question?
Which banks lend to non-residents?
Get our bank ranking for expats and non-residents, updated for 2026, and find out which banks to submit your application to.
Thank you! Your ranking is ready.
Download the PDF ↓