Advising Americans in France: A Compliance Checklist for Wealth Firms

If your firm advises clients in France, some of them are likely American: US citizens, green card holders or dual nationals. France and the US both want to know about their accounts, and each country's favourite savings products can cause problems in the other.

Here is what to track, who files what, and where your role ends.

France fines each undeclared foreign account separately, and a US brokerage or bank account becomes foreign the moment the client is French resident. Missed declarations are among the most common and most avoidable problems for Americans in France.

1. France: the annual income tax return
   French residents declare worldwide income each spring. Online deadlines fall in late May or early June depending on the department; in 2026 they were 21 May, 28 May and 4 June.
2. France: Form 3916 for every account abroad
   Every account opened, held, used or closed during the year with an institution outside France must be declared with the return, including empty accounts and US accounts. Life insurance contracts with insurers outside France are declared too, on Form 3916-bis. The fine is 1,500 euros per undeclared account per year, or 10,000 euros for an account in a non-cooperative state.
3. France: IFI real estate wealth tax
   IFI applies when net taxable real estate exceeds 1.3 million euros on 1 January, including real estate held through companies, funds and the property share of some life insurance contracts. A client who was not French resident in the previous five years is taxed only on French real estate until 31 December of their fifth year of residence. After that, property they own in the US can come into scope, subject to the US-France treaty.
4. Flag assurance-vie for the US preparer
   Assurance-vie is France's default savings wrapper, but its US treatment is complex and depends on the contract and the funds inside. It is reportable on the FBAR and usually Form 8938. Agree the approach with the US preparer before recommending one to an American client.
5. US: FBAR and Form 8938
   French accounts count toward the $10,000 FBAR threshold, reported by each account's maximum balance. Form 8938 applies above $200,000 at year end or $300,000 at any time for a single filer abroad, double for joint filers. See FBAR vs Form 8938.
6. Watch for PFICs
   French and other European funds and ETFs are usually PFICs for a US person, with punitive default tax and usually a Form 8621 for each one. See our PFIC explainer.
7. Check US broker access
   US custodians often restrict accounts once the address is in France, and EU rules generally block retail purchases of US ETFs without a Key Information Document. If a letter has arrived, use our advisor playbook for restricted accounts.
8. Confirm who files
   Identify the client's US and French tax advisers and agree when your firm sends them the account data they need. The French account list and the US reports should describe the same accounts.

Checking one client quickly? Our free Expat Client Exposure Check flags custodian, FBAR, Form 8938, PFIC and French account declaration risk in six questions.

Unless your firm has the right tax expertise, leave preparing and signing these returns to qualified tax professionals in each country. Your role is making sure the financial picture is complete, including accounts held outside your firm.

Aequify connects a client's accounts across 30+ countries into one view, including assets held elsewhere, and produces tax-ready data packs with FBAR maximum balances and Form 8938 figures, plus one consistent account list the French accountant can work from. See how Aequify works for advice firms.

This article provides general information for advisers, not tax or legal advice. Rules and thresholds change, so confirm them with a qualified tax adviser for each client.