France-US Tax Desk | Cross-Border Tax Lawyers | Alphard Law

The France-US Tax Desk is Alphard Law's dedicated practice for individuals, families and businesses whose tax life straddles the Atlantic. Two sophisticated tax systems, two reporting cultures, and almost no natural coordination between them: that gap is where our work sits.

For US persons living in France, we handle the compliance stack that no single-country adviser fully sees: foreign trust reporting on Forms 3520 and 3520-A and their French mirror under Article 1649 AB of the French Tax Code, FBAR and FATCA obligations covering French bank accounts, assurance-vie policies and pension schemes, streamlined procedures for taxpayers coming back into compliance, and the treatment of French investments under the PFIC rules.

For French entrepreneurs and investors heading the other way, we advise on setting up in the United States: choice of entity and state, permanent establishment risk under the France-US tax treaty, executive relocation with its exit tax and stock-option questions, US real estate structuring, and the repatriation of American profits to France.

For families, we plan across the 1978 France-US estate and gift tax treaty, coordinate cross-border successions, and regularize structures inherited from another generation.

Every article in this section is written by a practitioner, cites primary sources verified on Légifrance and IRS.gov, and takes a position. Start with our cornerstone analyses of the trust double reporting trap, the streamlined procedures, and the French founder's US roadmap, or contact us for a confidential review of your situation.

France-US Tax Desk

US Trusts and France: the Double Reporting Trap (3520 / 1649 AB)

One trust, two tax administrations, zero coordination: how Franco-American families fall into the 3520 / 1649 AB double reporting trap, and the way out.
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