For people relocating from France to the United States

Moving to the US From France: Your First US Tax Year

Moving from France to the US changes your tax position in stages. This guide covers when US residency starts, the dual-status first year, the treaty tie-breaker and what happens to accounts you keep in France.

Substantial presenceGreen card testDual-status yearTie-breakerSocial security

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Quick answer

When does someone moving from France start paying US tax on worldwide income?

From the residency starting date: the first day in the US in a year you meet the substantial presence test, or the first day as a permanent resident under the green card test (IRS Pub 519). Before that you are a nonresident, so the first year is usually dual-status. If you are also resident in France, Article 4 (Resident) of the treaty decides which country you are resident in for treaty purposes.

Prepared by Illuminous Accounting · Sources checked November 11, 2026

At a glance

When you become US resident: Green card test or substantial presence test (Code section 7701(b))
First year: Usually dual-status: nonresident, then resident
Treaty tie-breaker: Article 4 (Resident)
Social security agreement: Yes, since July 1, 1988
Accounts in France: FBAR, Form 8938 and PFIC rules can apply once resident

The first US return after France

The first US return after leaving France is rarely a normal one.

Situation	What applies
Arrived mid-year and passed a test	Dual-status year: nonresident before the residency starting date, resident after it
Arrived late and passed neither test	Nonresident for the year, unless the first-year choice applies (31 consecutive days and 75% presence, plus the substantial presence test next year)
Married to someone still in France	Special rules let some couples choose to file as residents for the whole year

Source: IRS Pub 519. See also first-year green card tax.

When someone from France becomes a US tax resident

The US decides tax residence with two tests in Code section 7701(b), not by your visa label (IRS Pub 519). Arriving from France, you become a US resident for tax purposes in a year if either applies:

Green card test: you are a lawful permanent resident at any time in the year.
Substantial presence test: at least 31 days in the US this year, and 183 days over three years counting all days this year, one third of last year's and one sixth of the year before.

Count your days with our substantial presence calculator.

Resident in both countries: the US-France treaty tie-breaker

During the move you can be resident in both France and the US under each country's law. Article 4 (Resident) of the treaty has the tie-breaker for someone resident in both countries: it looks first at where you have a permanent home available, then at the further tests the article lists, in the order it sets them. If the treaty makes you a resident of France, you can be taxed as a nonresident of the US for the treaty's purposes, but that position must be disclosed on Form 8833 under Treas. Reg. section 301.7701(b)-7 (IRS Form 8833).

Green card holders should be careful: a long-term resident who claims treaty residence abroad this way may be treated as having expatriated under section 877A (IRS).

Your accounts back home

Once you are a US resident, bank, pension and investment accounts you keep in France can bring the FBAR and Form 8938, and funds held there are often treated as PFICs (Form 8621, IRS). See FBAR and FATCA and Form 8938 for who files and the thresholds.

Sources for moving from France

Treaty

The IRS lists the 1994 income tax treaty, signed August 31, 1994, amended by protocols listed for 2004 and 2009. General effective date (IRS Table 3): treaty Jan. 1, 1996; protocol Jan. 1, 2007; protocol Jan. 1, 2010 (IRS treaty documents for France; treaty text; IRS Table 3).
Residence and tie-breaker: Article 4 (Resident).
Saving clause: Article 29 (Miscellaneous Provisions).
Article 18 (Pensions), pensions.
Article 24 (Relief From Double Taxation), relief from double taxation.
Article 15 (Dependent Personal Services), employment income.

US law

US residency tests and starting dates: Code section 7701(b) (IRS Pub 519).
Treaty residence for dual residents: Treas. Reg. section 301.7701(b)-7, Form 8833 and section 6114; long-term residents: section 877A (IRS Form 8833).
Social security agreements: SSA list.

The rules of France on leaving the country also apply; check them with a local adviser.

How we help

Send us your arrival date, visa or green card dates and a summary of income and accounts in France. We confirm your US status for the year, prepare the dual-status or resident return with the reporting it needs, and Gurleen Kaur, CPA licensed in British Columbia and Washington State, signs. Quote before any work.

Common questions

Does my visa decide my US tax residence after moving from France?

When you meet the green card test or the substantial presence test (31 days this year and 183 weighted days over three years). Your residency starting date is generally your first day in the US that year, or your first day as a permanent resident.

What if I am resident in both France and the US?

Article 4 (Resident) of the treaty breaks the tie, starting with where you have a permanent home. Claiming treaty residence in France on a US return needs Form 8833.

Do I report my accounts in France after moving to the US?

Once you are a US resident, yes: the FBAR when foreign accounts total more than US$10,000, Form 8938 above higher thresholds, and PFIC rules for many foreign funds.

Is there a US social security agreement with France?

Yes, in force since July 1, 1988.

Sources

Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.

Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 11, 2026. This page is general information, not tax or legal advice for your situation.

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