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 Heirs of French Estates: Form 706-CE, Succession Tax and the Treaty

Franco-American successions in both directions: the US heir of a French parent (French duties, Form 3520, basis step-up, inherited funds) and the American citizen dying in France (Form 706, 706-CE credit, non-citizen spouse).
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FATCA at Fifteen: What the Data Says About the Compliance Gap

The fifteen-year FATCA record assembled from official audits: the discovery machine that works, the enforcement that ran late, the burden that fell on the compliant, and the window the data describes.
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French Executives Moving to the US: Exit Tax, Stock-Options, BSPCE

The three mechanisms that fire on the executive's departure date: the exit tax with its deferral and discharge, the sourcing split of options and BSPCE after the 2026 reform, and the American entry without step-up.
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French Assurance-Vie Through American Eyes: PFIC or Grantor Trust?

Why the assurance-vie fails the American definition of insurance, the PFIC arithmetic of what it contains, the grantor trust minority thesis, and the four-question triage for existing contracts.
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Delaware, Wyoming or Where You Actually Operate? A Tax Reality Check

What the certificate of incorporation governs, what nexus taxes, when Delaware and Wyoming genuinely earn their reputations, and the three-question grid for the French founder.
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