Tax residence in France for U.S. citizens and green card holders

France treats you as tax domiciled there if any one test is met: your home (foyer) or principal stay, your main professional activity, or your center of economic interests is in France. Since 2025 French law expressly yields to a treaty that makes you resident elsewhere. U.S. citizens remain taxable in the United States; the U.S.–France treaty settles dual residence.

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Free, no sign-up, about 3 minutes. Conclusion under U.S. law, compared with the law of France and the tax treaty.

When France treats you as a tax resident

France treats you as domiciled if any one of three tests is met: foyer (household) or principal place of stay in France; principal professional activity in France; centre of economic interests in France.

Your family lives in France — that is your foyer, so under art. 4 B CGI you are domiciled in France and taxable there on your worldwide income.
Your principal professional activity is in France (including remote work performed from France for a U.S. or other foreign employer) — under art. 4 B 1 b CGI you are domiciled in France.
The centre of your economic interests is in France — under art. 4 B 1 c CGI you are domiciled in France.
With no family, main work or economic centre in France, your principal place of stay decides: more than six months a year in France — you are probably domiciled in France.

When you are a nonresident

None of the art. 4 B CGI tests is met — you are not domiciled in France. French-source income (including pay for work physically done in France) is still taxable there.

Where the rules of France clash with U.S. tax rules

Collision: U.S. citizens stay taxable in the United States even as French residents. France taxes you on worldwide income because you are domiciled there; the United States taxes its citizens on worldwide income wherever they live. Even if the treaty tie-breaker makes you a resident of France, the saving clause (Art. 29(2)) lets the United States tax you as if the Convention did not exist. Double tax is relieved under Art. 24, which the saving clause keeps (Art. 29(3)): France first, then the United States credits French tax on income re-sourced as French (Art. 24(2)(b)).
Collision: your main work in France is enough for France. For France, carrying on your principal professional activity in France — including remote work from France for a U.S. employer — is on its own a ground for domicile, even if your home and family are in the United States. The conflict is resolved by Art. 4(4) of the Convention: if your only permanent home is in the United States, you are a U.S. resident for the treaty, and since 16 Feb 2025 French law then no longer treats you as domiciled in France. Your salary for days physically worked in France can still be taxed in France unless all conditions of Art. 15(2) are met.
Collision: the centre of economic interests is enough for France. If most of your income or investments are in France, France treats you as domiciled there even if you live in the United States. U.S. law has no such test. Art. 4(4) of the Convention decides — permanent home first. Property in France counts only if it produces income (Conseil d'État no. 426124), and French courts must apply the treaty tie-breaker once a residence conflict exists (Cour de cassation no. 19-14.013).
Collision: family in France is a foyer. If your spouse or partner and children live in France, France treats you as domiciled there even if you spend most of the year in the United States. Under the Convention: if your only permanent home is in the United States, you are a U.S. resident for the treaty; if you have a permanent home in both countries, family usually pulls the centre of vital interests to France. U.S. citizens remain taxable in the United States in any case (Art. 29(2)).

What else to know

Treaty residence test for U.S. citizens and green-card holders. France regards a U.S. citizen or green-card holder as a U.S. resident for the Convention only if he or she stays principally in the United States, or would be a U.S. resident under the permanent-home / vital-interests / habitual-abode tests (Art. 4(2)(a)). If you live in France and have no such link to the United States, France treats you as a resident of France only — the nationality step of the tie-breaker does not help you. The tie-breaker itself is Art. 4(4).
Since 2025 the treaty expressly prevails in French law. Since 16 Feb 2025 art. 4 B CGI states that a person who is not a resident of France under a tax treaty is not domiciled in France. If the tie-breaker of the U.S.–France Convention (Art. 4(4)) makes you a U.S. resident, France taxes you only as a non-resident.
Pay for work done in France. If you are a U.S. resident under the Convention, France may tax your pay for work physically done in France unless all conditions of Art. 15(2) are met: no more than 183 days in France in any twelve-month period beginning or ending in the tax year, an employer that is not a French resident, and pay not borne by a French permanent establishment. French withholding applies under art. 182 A CGI; the United States relieves double tax by its foreign tax credit (Art. 24(2)).
French impatriate regime (art. 155 B CGI). If you were not tax-domiciled in France in the five calendar years before taking up a job there, the impatriate regime can exempt your impatriation premium (actual amount, or a flat 30% of net pay) and pay for work abroad (capped at 50% of total pay, or 20% for the work-abroad part), plus 50% of certain foreign investment income and gains, until 31 December of the eighth year after you start. There is no nationality condition. For a U.S. citizen the exemption lowers French tax only — your U.S. tax is computed under U.S. law, and lower French tax means a smaller foreign tax credit.
CSG/CRDS and the U.S. foreign tax credit; social security. In 2019 the United States and France confirmed that CSG and CRDS are not social taxes covered by the U.S.–France Social Security Agreement, and the IRS no longer challenges foreign tax credits for them. Social security contributions themselves follow the agreement (in force since 1 Jul 1988): as a rule you are covered only where you work; employees temporarily sent from the United States can stay in U.S. Social Security with a certificate of coverage.
Year of arrival or departure. In the year you arrive in or leave France, the six-month guideline is not applied: France taxes you as a resident only for the period of actual residence. The U.S. tax year is also the calendar year, but U.S. citizens are taxed for the whole year regardless of where they live.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(4) of the treaty applies: Convention between the Government of the United States of America and the Government of the French Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital (signed 31 August 1994, amended by the Protocols of 8 December 2004 and 13 January 2009). The tests are applied in order — permanent home, center of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities. U.S. citizens remain taxable in the United States under the saving clause.

Terms you will come across in France

domicile fiscal: tax domicile under art. 4 B of the General Tax Code
foyer: home where your family lives
lieu de séjour principal: place of principal stay
centre des intérêts économiques: center of economic interests
attestation de résidence fiscale: certificate of tax residence
retenue à la source: tax withheld at source

Questions

I am a U.S. citizen — do I still pay U.S. tax if I live in France?

Yes. The United States taxes its citizens on worldwide income wherever they live, and the treaty keeps that right through the saving clause (Art. 29(2)). You file Form 1040 every year; double taxation is relieved mainly by the foreign tax credit (Form 1116) or the foreign earned income exclusion (Form 2555), plus the treaty's relief article (Art. 24).

Which treaty applies between the U.S. and France?

The Convention signed on 31 August 1994 (in force 30 December 1995), with Protocols of 8 December 2004 and 13 January 2009. Since the 2009 Protocol the tie-breaker is in Art. 4(4).

Can I claim a U.S. foreign tax credit for CSG and CRDS?

Yes. In 2019 the United States and France confirmed that CSG and CRDS are not covered by the U.S.–France social security agreement, and the IRS no longer challenges foreign tax credits for them.

Sources

Legislation and official guidance

art. 4 A CGI — Individuals domiciled in France for tax purposes pay income tax on their worldwide income; others only on French-source income.
art. 4 B CGI (as amended by art. 83 of Law no. 2025-127 of 14 Feb 2025, in force from 16 Feb 2025) — You are domiciled in France if (a) your foyer (household) or principal place of stay is in France, OR (b) you carry on your principal professional activity in France, OR (c) the centre of your economic interests is in France. One criterion is enough. Since 16 Feb 2025: if you are not a resident of France under a tax treaty, you are not domiciled in France under French law either.
impots.gouv.fr — «Suis-je non-résident fiscal ?» — The foyer is where your spouse or PACS partner and children live, even if you yourself spend most of the year abroad; tax-treaty criteria take precedence.
BOFiP BOI-IR-CHAMP-10-20160728 — Foyer = where the family normally lives; principal place of stay = guideline of more than six months a year, not absolute; principal activity = the one you devote most time to; centre of economic interests = main investments, seat of business, most of your income; one criterion is enough.
art. 164 B CGI — Income from professional activity performed in France is French-source income.
art. 182 A CGI (version from 1 Jul 2026) — French withholding tax applies to French salaries of non-residents: 12% and 20% above set thresholds.
Art. 29(2)–(3) U.S.–France Convention (saving clause, as replaced by the 2009 Protocol) — Notwithstanding the Convention (except para. 3), the United States may tax its residents and citizens as if the Convention had not come into effect; former citizens and long-term residents remain covered for ten years. Para. 3 keeps, among others, Art. 24 (relief), Art. 25 (non-discrimination) and Art. 26 (mutual agreement) for everyone.
Art. 24(1)(b) U.S.–France Convention — For an individual who is both a resident of France and a U.S. citizen, France extends its credit equal to the French tax to listed U.S.-source dividends, interest, royalties and certain gains, provided the individual proves compliance with U.S. federal income tax obligations; U.S. tax levied only under the saving clause (Art. 29(2)) is not counted as U.S. tax paid for the French credit.
Art. 24(2)(b) U.S.–France Convention — For a U.S. citizen resident in France, the United States credits the French income tax paid after the French credit; this credit may not reduce the part of U.S. tax that France credits; the relevant income is treated as French-source income to the extent necessary, but only insofar as it is included in gross income for French tax purposes.
Art. 4(2)(a) U.S.–France Convention — France regards a U.S. citizen or green-card holder as a U.S. resident only if he or she stays principally (has a substantial presence) in the United States, or would be a U.S. resident — and not a resident of a third State — under the permanent-home / vital-interests / habitual-abode tests.
Art. 4(4) U.S.–France Convention (renumbered from Art. 4(3) by the 2009 Protocol) — Dual-resident individual: (a) permanent home; if in both States — centre of vital interests; (b) if that cannot be determined or there is no permanent home in either State — habitual abode; (c) then nationality; (d) otherwise mutual agreement of the competent authorities.
Art. 15(2) U.S.–France Convention — Salary of a resident of one State for work in the other State is taxable only in the residence State if presence there does not exceed 183 days in total in any twelve-month period beginning or ending in the tax year concerned, the employer is not a resident of the work State, and the pay is not borne by the employer's permanent establishment or fixed base there.
art. 155 B CGI — impots.gouv.fr «Le régime des impatriés» — For people who were not tax-domiciled in France in the five calendar years before taking up the job: the impatriation premium (actual, or a flat 30% of net pay on option) and pay for work abroad in the employer's interest are exempt (caps: 50% of total pay overall, or 20% for the work-abroad part), plus a 50% exemption of certain foreign passive income and gains, until 31 December of the eighth calendar year after taking up the job. No nationality condition.
IRS — «Totalization agreements» — In 2019 the United States and France confirmed through diplomatic communications that the French CSG and CRDS are not social taxes covered by the U.S.–France Social Security Agreement; the IRS will not challenge foreign tax credits for them on that basis.
IRS Practice Unit «French Foreign Tax Credits» (DCN FTC/T/010_01-01, rev. 08/28/2019) — The IRS no longer challenges the creditability of CSG and CRDS for the U.S. foreign tax credit.
SSA — «U.S. International Social Security Agreements» — Agreements with France in force from 1 Jul 1988 and with Italy from 1 Nov 1978; basic territoriality rule — an employee is covered only where he or she works; detached-worker rule generally for assignments expected to last 5 years or less.
SSA — U.S.–France agreement pamphlet — To be exempt from U.S. Social Security on the basis of French coverage, the employer must request a certificate of coverage (SE-404-1 / SE-404-2) from the French agency; self-employed people transferring activity for two years or fewer stay in their home system.
Art. 4(4)(a) of the Convention — A dual-resident individual is deemed a resident of the State in which he or she has a permanent home available (foyer d'habitation permanent); if there is a permanent home in both States, of the State with which personal and economic relations are closer (centre of vital interests).
Art. 4(4)(b) of the Convention — If the centre of vital interests cannot be determined, or there is no permanent home in either State: resident of the State where he or she has an habitual abode (séjourne de façon habituelle).
Art. 4(4)(c), (d) of the Convention — Habitual abode in both States or in neither: resident of the State of nationality; nationality of both or neither: the competent authorities settle the question by mutual agreement.
Art. 26 U.S.–France Convention — Mutual agreement procedure: a case can be presented to the competent authority within three years of the first notification of the action; paras. 5–6 (2009 Protocol) add arbitration.

Case law

Conseil d'État (France), no. 450692, 2022-05-11 — The foyer of a single person is the place where he or she normally lives and has the centre of personal life, disregarding temporary stays elsewhere for work or exceptional reasons; the principal place of stay matters only where there is no foyer.
Cour de cassation (France), commercial chamber, no. 15-27.364, ECLI:FR:CCASS:2017:CO00562, 2017-04-26 — Foyer and centre of interests in France were established by facts: two houses, registration on electoral rolls, substantial electricity consumption, accounts only in French banks, French health insurance; a third party's statement about renting a home abroad, without rent receipts, did not rebut this. Wealth tax (ISF) case.
Conseil d'État (France), no. 469771, 2024-02-05 — The CEO of a French company whose family lived in Switzerland was domiciled in France under the principal-professional-activity test; occasional remote work from abroad did not change this. (The Court's view on the effect of the treaty for withholding purposes was overridden by statute from 16 Feb 2025.)
Conseil d'État (France), no. 426124, 2020-10-07 — The centre of economic interests cannot be established merely from owning companies and real estate in France: the court must check whether they generate income and compare it with income abroad.
Cour de cassation (France), commercial chamber, no. 19-14.013, ECLI:FR:CCASS:2021:CO00809, 2021-11-24 — Where France treats a person as domiciled under art. 4 B CGI (here: centre of economic interests) and another State also treats the person as its resident, there is a residence conflict and the court must apply the treaty tie-breaker. Wealth tax (ISF) case; same residence criteria.
Cour de cassation (France), commercial chamber, no. 19-13.710, ECLI:FR:CCASS:2021:CO00698, 2021-10-13 — A dwelling the person kept in France for his own long-term use is a permanent home under the treaty even if he also has a house abroad; where personal ties were split between the two States, economic ties (almost all income and assets in France) decided the centre of vital interests. Wealth tax (ISF) case; same criteria.
U.S. Court of Appeals for the D.C. Circuit, Eshel v. Commissioner, No. 14-1215, 2016-08-05 — Reversed the Tax Court's holding that CSG and CRDS are covered by the U.S.–France totalization agreement (which would bar a foreign tax credit) and remanded; the court did not itself decide coverage. The issue was later settled administratively by the 2019 U.S.–France understanding.

Updated 2026-11-04. The result is for information only and is not tax or legal advice. Tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes. Consult a qualified adviser before making decisions.

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