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

Accidental Americans in Europe: Comply, Renounce, or Wait?

The three exits from accidental American status examined honestly: streamlined compliance, renunciation at the new $450 fee with the dedicated relief procedures, and the narrow case where waiting is defensible.
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Why France-US Tax Compliance Fails: Ten Structural Mismatches

The framework article of the France-US Tax Desk: ten structural mismatches between the two systems, why competent national advisers still produce failures, and the single-file method.
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Permanent Establishment in the US: the French Company's Risk Map

The Article 5 risk map for French companies in the American market: classic triggers, the safe harbors the 1994 treaty still protects, the modern gray zones, and the cost of getting it wrong.
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FBAR for Americans in France: Assurance-Vie, PEA, Forgotten Accounts

The FBAR captures the assurance-vie, the PEA, joint accounts and accounts held under mere signature authority: the complete inventory method, the post-Bittner penalty math, and the repair channels.
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Setting Up in the United States: a French Founder's Tax Roadmap

Presence, vehicle, mobility: the three questions of a US expansion, answered in the only order that avoids double taxation, and the traps of the LLC reflex and the incorporation myth.
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