France–United States — The Riviera Private Wealth Brief

0Executive summary

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

1The France–United States conventions — 1994 and 1978

The relationship rests on two instruments. The convention of 31 August 1994 on income and fortune, in force since 30 December 1995, replaced the 1967 text and has been amended by the avenants of 8 December 2004 and 13 January 2009; it carries a protocol and exchanges of letters, a detailed limitation-on-benefits article of the kind the United States negotiates (article 30), and — unusually in France's network — the wealth tax within its scope. The succession and gift convention of 24 November 1978, in force since 1 October 1980 and amended by the avenant of 8 December 2004, is one of the few succession treaties France has concluded, and it governs lifetime gifts and the American generation-skipping transfer tax as well as estates. Neither instrument is modified by the BEPS multilateral convention, which the United States has not signed; the bilateral texts, as amended, state the law. Both were done in French and English, the two texts equally authentic — this brief quotes the French consolidation, the English official text standing beside it.

Residence does the sorting — and citizenship then makes its own claim. A person taxable in both states is assigned by the tie-breakers of article 4 of the 1994 convention: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. The 1978 convention runs a domicile article to the same design and adds a clause of direct interest to families in their first French years: a national of one state domiciled in both remains treaty-domiciled in the state of nationality while French domicile has lasted under five of the preceding seven years and no indefinite stay is intended (article 4 §3). Above the tie-breakers, however, sit the citizen clauses of article 29 §2 and article 1 §4: whatever the treaty assignment, the United States may tax its citizens as if the conventions did not exist, subject to listed exceptions that preserve, principally, the elimination, non-discrimination and mutual-agreement articles. The practical consequence runs through every section of this brief: for a US citizen the conventions do not exempt, they organise credits.

The American side keeps its own accents. The United States taxes its citizens on worldwide income wherever they live; its federal estate and gift tax proceeds from a large unified exclusion rather than from kinship-based scales; the conventions cover federal taxes only, so state-level taxation stands outside them (1994 convention, article 2 §1 b); and the family instrument of habit is the trust. This brief states American law at orientation level only; its verified ground is the French side and the two conventions, and the American reading belongs with the family's US counsel.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1994 convention arts. 2, 4, 29 §§1–3, 30; 1978 convention arts. 1, 2, 4; BOI-INT-CVB-USA (19 Feb 2020 update; older chapters — the text prevails)

2The market seen from the United States

Seen from the United States, the Riviera's €3M+ villa market leads with Cannes. Cannes and its hills — the Super Cannes quarter on the Vallauris side included — contributed 306 qualified sales for €2,066M across 2014–2025, at a €4.9M median and a €46.5M ceiling, with 37% of value in eight-figure transactions. The Saint-Tropez peninsula remains the largest €3M+ register on the coast, at 1006 sales for €7,049M, while Saint-Jean-Cap-Ferrat is its narrowest and most expensive: 178 sales for €2,375M at a €6.5M median and a €200.0M ceiling. The past 36 months alone account for €3,970M across the three.

Source: DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales ≥ €3M, 2014–2025, estate-deduplicated — the same convention as the published Riviera Intelligence hub, so this brief and the public pages cannot disagree. DVF through 2025-12-31.

Ownership, in aggregate

The public record itself describes how the Riviera is held. This brief reads it in aggregate — the State's transaction register alongside the public company registers, all of it already published, anonymised in processing, and with no individual holding ever identified. Across 20 Riviera communes, 29% of the ownership positions studied are held from outside France. American residence appears in the current study at roughly 2% of foreign-held positions — a presence the register records only faintly. The case this brief addresses is accordingly prospective rather than installed: the American families it concerns are, for the most part, buyers the coming decade will record rather than owners the last one already has.

Aggregates only, drawn from public sources under their re-use conditions; no individual holding is identified or published. Residence attribution follows the address of record. Figures refresh with each edition.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · DVF register, estate-deduplicated · ownership aggregates from public registers only

IBuying in France as a US resident

The process and its costs

The acquisition follows the standard French sequence: offer, compromis de vente with a ten-day cooling-off period, deposit of customarily 10%, conditions precedent, and the authentic deed before the notaire, who collects the duties and registers title. The notaire acts as a public officer rather than as the buyer's counsel, and American buyers typically retain their own advisers in addition — on both sides of the Atlantic, since the vehicle chosen at the deed has United States consequences of its own. The structure questions of section I bis, the trust above all, deserve answers before the compromis is signed; the acquiring vehicle is difficult to change once the process is under way.

The cost of owning

CGI article 964 institutes the annual tax on real-estate wealth above €1,300,000 of taxable assets. For persons not domiciled in France the base comprises French-situs property together with the fraction of any company's shares representing French property (article 964-2°), and the treaty position is settled rather than absent: article 23 §1 of the 1994 convention assigns wealth constituted by French real estate, and by shares of companies more than half of whose value derives from it, to France, and the administration's commentary places the IFI within the convention through the analogous-tax clause of article 2 §2. A US-resident owner therefore bears the IFI with the treaty's confirmation rather than its shelter; the United States, levying no federal wealth tax, leaves the charge single. Interests in entities other than companies — a trust among them — follow the same logic where their value derives from French real estate (article 23 §1 c).

For the family weighing a full move to France, two five-year clauses run in parallel. French law taxes any new resident, after five years abroad, on French assets only for five years (article 964-1°, al. 2). Article 23 §6 of the convention grants US citizens without French nationality the same five-year exclusion of non-French assets as a treaty right — one France cannot narrow unilaterally — and renews it where the person, having ceased to be a French resident for at least three years, later returns. Under the worldwide ISF the clause was among the most valuable in the treaty network; under the IFI, whose base is real estate alone, its practical work has narrowed to what the domestic rule already covers. The constant is the villa: French real estate stood outside both shelters in every era.

Recurring charges follow the property. Taxe foncière runs at communal rates; for furnished secondary residences, communes in the zone tendue — a category that includes the marquee Riviera communes — may vote a surtaxe on the taxe d'habitation for second homes, and the annual occupancy declaration is required of all owners. Because these rates are communal and year-specific, this brief's edition cycle re-verifies them rather than freezing them. The American counterpart is stated once and stands for every section: a US citizen or resident reports the villa's events — imputed nothing while it stands empty, rental income when let, gain when sold — on the federal return, with the credit machinery of article 24 doing the ordering.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965; 1994 convention arts. 2 §2, 23 §§1, 6; cost scales stated for orientation, itemised at engagement

I bisStructures, as questions

The structure question

Holding structures are presented here, in keeping with this line's doctrine, as questions for analysis rather than as recommendations. For an American buyer the analysis carries one organising fact: instruments that are ordinary at home — the revocable living trust above all — meet a French system that has its own statute for them, and the meeting deserves to be priced before the deed, not after.

The trust, before French law

French law does not know the trust as an ownership form, and has therefore given it a statute of its own — three texts, each verified against the corpus, that together describe what an American settlor should expect. First, reporting. The administrator of any trust whose settlor or any beneficiary is French-resident, or which includes an asset situated in France — a Riviera villa satisfies the condition by itself — must declare the trust's constitution, terms, modifications and extinction, and file annual valuations (CGI article 1649 AB); the penalty regime attached to the obligation has been upheld by the Conseil d'État. Second, the wealth side. Trust assets within the IFI's scope are simply included in the settlor's taxable estate, or in that of a beneficiary deemed settlor (article 970); the dedicated levy of article 990 J, at the top IFI rate, stands behind the declarations and is not due where the assets have been regularly included and declared — a backstop for the undeclared rather than an extra cost for the compliant. Third, transmissions. Where a transfer through a trust can be qualified as an ordinary gift or succession, the ordinary duty applies by kinship; where beneficiaries' shares are determined at death, kinship rates likewise apply; but a share due globally to descendants bears the top direct-line rate, an undetermined remainder bears the top rate of the third table — 60% — and a trust administered from a non-cooperative jurisdiction reaches that rate regardless of kinship (article 792-0 bis). The familiar American revocable trust, transparent at home, therefore answers to an entirely different regime once a French villa sits in it: nothing about it is transparent to French duty, and the determination of beneficiaries' shares becomes the central drafting question. The 1978 convention does not displace this machinery — the villa answers to France as situs state (article 5) — and how a particular trust's transmissions map onto the treaty's articles is examined with counsel on both sides at engagement. In practice, families who intend the villa for a trust generally weigh the alternative of holding it outside the trust and letting the treaty's own succession architecture, described below, do the work.

Debt against the IFI — what the code anticipates

The financing conversation runs here as it does elsewhere on this coast: a loan from the buyer's bank, secured on a pledged portfolio, so that liquidity remains invested while the debt reduces the taxable base. The mechanics are lawful and the code anticipates them. Acquisition debt owed to a bank is deductible from the IFI base under CGI article 974, while financial assets sit outside that base altogether. The boundaries are three. Loans repaying capital at term are deemed to amortise, the deduction declining pro rata over the loan's life, and by one twentieth a year where no term is fixed. Where taxable property exceeds €5M and debts exceed 60% of its value, the excess is deductible only as to half, unless the borrower shows the loan was not contracted mainly for tax. And the debt must be real — actually drawn, actually serviced, at market terms; routed through a shareholder account of an SCI it ceases to count for valuing the shares (article 973). Leverage moderates the IFI in its early years and fades by design — a calendar best examined before the compromis rather than after. The 1978 convention adds a succession counterpart of its own design: debts are deducted from the taxable estate in the proportion the assets taxable in each state bear to the whole (article 9).

What the acquisition decides for succession — and for gifts

The 1978 convention governs succession duty and gift duty alike, a reach most French succession treaties lack. Its architecture is settled. The villa answers to French duty as the state where it stands, for estates and for gifts (article 5 §1); shares in a company more than half of whose assets, directly or through interposed entities, are French real estate are treated as the real estate itself (article 5 §3); intangible property and cash follow the deceased's or donor's domicile or citizenship (article 8). Where the deceased was domiciled in France, France taxes the worldwide estate and credits the American tax (article 12 §2 a); the United States, where it also taxes, credits the French duty on French-situs assets (article 12 §2 b), and for a US citizen domiciled in France it credits the French tax across the estate. The 2004 avenant then eased the American side for cross-border families: a treaty marital deduction for property passing to a surviving spouse who is not a US citizen, on an executor's election that waives the domestic alternatives (article 11 §3), and, for the estate of a France-domiciled non-citizen, a unified credit computed pro rata to the American share of the worldwide estate where that exceeds the ordinary non-resident credit (article 12 §3). France, for its part, grants a US-domiciled deceased's estate the same allowances and credits as if the person had died domiciled in France (article 12 §4) — so the €100,000 per-child allowance of CGI article 779 and the spouse's succession exemption apply to the villa whichever side of the Atlantic the family lives on, ahead of the scale of article 777, progressive to 45% in the direct line.

Before either state determines the duty, the civil law determines who inherits, and here the relationship carries a genuine tension. American testamentary freedom and French forced heirship answer the same question differently, and EU Regulation 650/2012 lets a US citizen habitually resident in France elect the law of his or her nationality for the succession as a whole. The election is not the end of the analysis: since the law of 24 August 2021, where the deceased or a child is a national or habitual resident of an EU member state and the foreign law applicable to the succession allows no reserved-share mechanism for children, each child may take a compensatory levy on assets situated in France — the villa first among them — up to the French reserved share (Civil Code, article 913, al. 3). A French villa is, in other words, the asset on which the two traditions meet; the will, the matrimonial regime carried into the purchase, and the calendar of any gifts are questions for counsel on both sides, best answered before the compromis. The five-of-seven-years domicile clause of article 4 §3 gives the family's first French years a treaty answer of their own.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 669, 751, 777, 779, 968–970, 973–974, 990 J, 1649 AB, 792-0 bis; 1978 convention arts. 5, 8, 9, 11, 12; Civil Code art. 913; EU Reg. 650/2012

IISelling as a US resident

France taxes first. Article 13 of the 1994 convention assigns gains on French immovables to France, and its definition of French real property reaches shares of companies more than half of whose value derives from French real estate, together with interests in partnerships, estates and trusts to the extent of their French property (article 13 §2 a). For a US-resident seller the French charge runs under CGI article 244 bis A: the taxable gain is reduced by an ownership-duration allowance of 6% for each year of ownership beyond the fifth and 4% for the twenty-second (article 150 VC), the income-tax component then applying at 19% (article 200 B) and extinguishing after 22 years. Taxable gains above €50,000 bear in addition the progressive surcharge of article 1609 nonies G, which reaches 6% at the levels this market transacts.

Two features distinguish the American seller's file from a European one. The United States sitting outside the European Union, the seller must in principle appoint an accredited fiscal representative in France, who signs the gain computation and answers for it; the administration grants an automatic dispensation where the price does not exceed €150,000 per seller or where the duration allowances have extinguished both the tax and the levies, thresholds a Riviera villa rarely meets. And the social levies apply at their full rate: the carve-out that reduces EU-affiliated sellers to the 7.5% solidarity levy rests on the European coordination regulation and does not extend to American affiliation — the Conseil d'État, ruling on a United States resident's sale, confirmed that the levies apply and that the free movement of capital offers no escape (CE, 31 March 2021, n° 436412). The levies extinguish after thirty years of ownership. One American mechanism then softens what the French computation has hardened: since 2019 the Internal Revenue Service recognises the CSG and CRDS as creditable taxes within the 1994 convention — a recognition the French administration has recorded in its own commentary — so the largest part of the levies enters the ordinary foreign-tax-credit machinery of the American return rather than being lost.

The United States then taxes the same gain, since the saving clause keeps its citizens and residents within the American base; the treaty answers with the credit of article 24 §2, and France's own credit rule for US-source gains (article 24 §1 a iii) completes the ordering where the seller is a France-resident citizen. The net of the two computations — French tax settled first, American tax reduced by it — is a matter of arithmetic on the family's actual basis and holding period, run at engagement; what the treaty guarantees is the order, not an exemption. Where the property is held through a company, the choice between selling the asset and selling the shares alters the pool of buyers, the French analysis and the American one; that choice is best evaluated before marketing begins rather than in the course of negotiation.

Leaving after the sale — a note on the exit tax

Families who sell and then move away from France sometimes ask whether an exit charge applies on departure. The answer is narrower than the name suggests. France's exit tax (CGI article 167 bis) is aimed at securities, not at property: it concerns persons who were French-domiciled for at least six of the ten years before leaving, and taxes the unrealised gains on substantial securities holdings — positions whose combined value exceeds €800,000, or stakes of 50% or more in a company's profits, the second criterion catching a controlling holding whatever its value — as they stand on the day of departure. A villa already sold has settled its own tax under the regimes above, and the sale proceeds themselves are not within the charge. Shares of a family SCI follow the property rather than the portfolio: so long as the company keeps the ordinary income-tax regime, gains on its property-rich shares remain within the real-estate regime (CGI article 150 UB) and outside the exit tax — the French right to tax a later sale being preserved instead by article 244 bis A. A company that has opted for corporation tax changes the classification, and with it the analysis; the option belongs on the pre-departure checklist. The residence clock matters equally: a person who leaves before six years of French domicile within the preceding ten stands outside the latent-gains charge altogether, so the family that tried France for a few years and moved on typically departs untouched; gains already placed under a tax deferral follow their own rules and are reviewed at engagement. Where the machinery does apply, payment is generally deferred, and the assessment lapses automatically where the securities are still held two years after departure — five where the portfolio exceeded €2.57M — or upon a return to France. For most sellers the exit tax is therefore a question of calendar and paperwork rather than of cost; the destination-specific mechanics of the deferral, for a return to the United States as for anywhere else, are settled at engagement.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1994 convention arts. 13, 24, 29 §2; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A, 1609 nonies G; CE 31 Mar 2021 n° 436412

IIIRenting — as tenant and as owner

Renting as a tenant

A rental year before purchase remains the classic first step, and it carries one caution worth stating clearly: French tax domicile under CGI article 4 B turns on the location of the foyer, the principal place of stay, and the centres of professional and economic interest — none of which defers to a lease. A Riviera villa that becomes the family's effective home can establish French residence well before any purchase; for an American family the consequence is not an exchange of one tax system for another but the addition of a second, the United States retaining its citizens under article 29 §2 while the tie-breakers of article 4 and the credit machinery of article 24 organise the overlap. The treaty windows of articles 23 §6 and 4 §3, described above, then give the calendar of those first years a value of its own. The choice between furnished seasonal lettings and the one-to-three-year civil lease determines exit flexibility, and is best matched to the trial's real purpose.

Renting the villa out

French-source rental income of non-residents — the furnished lettings common at this price point included — is taxed under the minimum-rate regime of CGI article 197 A, at no less than 20% up to the second-bracket ceiling and 30% above it, unless the taxpayer demonstrates a lower worldwide effective rate; social levies apply in addition, at the full rate for American-affiliated owners, as for the sale above. The convention assigns the income to France as the state where the property stands (article 6 §1), and permits an owner taxed there to elect a net basis where domestic law does not already provide one (article 6 §6) — French law does, the furnished-letting regimes computing rental income net of charges or of a standard allowance, at mechanism level here and itemised at engagement. On the American side the same rents enter the federal return under the citizen and residence rules, with the French tax credited under article 24 §2; the CSG and CRDS borne on the rents share, since 2019, in the creditable-tax recognition noted in section II.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A; 1994 convention arts. 6, 24 §2, 29 §2

4What changed

Edition 1 — baseline (July 2026). The instruments as they stand: the convention of 31 August 1994 as amended by the avenants of 8 December 2004 and 13 January 2009, and the succession and gift convention of 24 November 1978 as amended by the avenant of 8 December 2004. Neither is modified by the BEPS multilateral convention, which the United States has not signed; no later instrument is recorded by either administration. The most recent movement in the relationship is administrative rather than conventional: the Internal Revenue Service's recognition, in July 2019, of the CSG and CRDS as creditable taxes within the 1994 convention, recorded by the French administration in its commentary of 19 February 2020 — the same commentary that reads the IFI into the convention's scope. Watch items for edition 2: annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; the calendar of the American estate-tax exclusion, whose level American families plan against; and any refresh of the administration's 2012–2015-vintage commentary on the fortune and succession articles, which this brief reads subject to the treaty texts. The ownership aggregates of section 2 are refreshed with each edition.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

5Questions, answered

Does a US resident pay French wealth tax on a Riviera villa?

Yes, once French real-estate assets exceed €1.3M, whether held directly or through the property fraction of company shares (CGI art. 964). The 1994 convention covers wealth tax and assigns French-situs property wealth to France (art. 23 §1); the United States levies no federal wealth tax, so the charge is confirmed by treaty yet never doubled.

Does moving to France expose an American's worldwide assets immediately?

Not to French wealth tax. Article 23 §6 of the 1994 convention keeps a US citizen's non-French assets out of the French wealth-tax base for five years after the move, and French law itself now taxes every new resident on French assets only for five years (art. 964-1°). The American side is unchanged by the move: a US citizen remains taxable in the United States on worldwide income wherever resident (art. 29 §2), with the treaty ordering the credits.

Who taxes the gain when a US resident sells a French villa?

France first, as the state where the property stands (1994 convention, art. 13), under CGI article 244 bis A with the ownership-duration allowances — the income-tax component extinguishing after 22 years and the social levies after 30. The United States then taxes the same gain under its citizen and residence rules and credits the French tax (art. 24 §2); since 2019 the IRS also treats the CSG and CRDS as creditable taxes.

Does an American seller need a fiscal representative in France?

In principle yes: sellers resident outside the EU and EEA must appoint an accredited representative for the gain computation (CGI art. 244 bis A). The administration grants an automatic dispensation where the price does not exceed €150,000 per seller or where the holding period has extinguished both the tax and the levies — thresholds a Riviera villa sale rarely meets.

Which country taxes the succession on a French villa?

France, as the situs state (1978 convention, art. 5), and property-rich shares are treated as the real estate itself. The United States, taxing its citizens and domiciliaries, credits the French duty (art. 12); France grants a US-domiciled deceased's estate the same allowances as if French-domiciled (art. 12 §4), and the 2004 avenant added a treaty marital deduction for non-citizen spouses (art. 11 §3).

Are lifetime gifts covered by the France–United States treaty?

Yes — a rarity in France's network. The 1978 convention applies to successions and gifts alike, the American generation-skipping transfer tax included (art. 2): a gift of the villa, or of its bare ownership, is taxed by France as the situs state, with the treaty's allocation and credit machinery ordering the American side.

Must an American trust be declared in France?

Yes, once it holds a French asset or a settlor or beneficiary is French-resident: the trustee declares the trust's constitution, terms and annual values (CGI art. 1649 AB). Trust assets within the IFI's scope are taxed in the settlor's hands (art. 970); the dedicated levy of article 990 J is not due where they have been regularly declared; and transmissions through the trust answer to article 792-0 bis, at rates that reach 60% where beneficiaries' shares are not determined.

Can a US citizen in France choose American law for the succession?

Largely, yes: EU Regulation 650/2012 lets a person elect the law of his or her nationality, and with it American testamentary freedom rather than French forced heirship. Since 2021, however, where the deceased or a child is an EU national or resident and the chosen law allows no reserved share, each child may take a compensatory levy on assets situated in France, the villa first among them (Civil Code, art. 913).

Does a French exit tax apply after selling and leaving?

Rarely, and never on the villa itself. The charge (CGI art. 167 bis) reaches only persons French-domiciled for six of the ten years before departure, and only their unrealised gains on securities — above €800,000 in value, or stakes of 50% or more of a company's profits; the sold villa and its proceeds stand outside, as do family-SCI shares kept under the ordinary income-tax regime (art. 150 UB). Where it does apply, payment is generally deferred and the assessment lapses after two years — five above €2.57M — or upon return to France.

What is the Chiron Legal Corpus?

The Chiron Legal Corpus is the research library behind this brief, maintained by this office's offshore legal-research partner: an extensive cross-border collection of consolidated statutes, tax-authority doctrine, treaty instruments and case law, including the French primary sources in full text. Every statement of law in these pages is verified against it, re-checked against Légifrance and BOFiP at each edition, and stamped with its review date section by section.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

6Methodology, sources & qualifications

Method. Legal statements are verified against the Chiron Legal Corpus, the research library maintained by this office's offshore legal-research partner — an extensive cross-border and international collection of consolidated statutes, tax-authority doctrine, treaty instruments and case law, including French primary law held in full text and re-checked against the official sources at each edition. The review of 19 July 2026 covered Légifrance (CGI arts. 4 B, 150 U, 150 UB, 150 VC, 164 A, 167 bis, 197 A, 200 B, 244 bis A, 669, 750 ter, 751, 777, 779, 964–970, 973–974, 990 J, 1609 nonies G, 1649 AB; Civil Code arts. 912–913 — consolidated texts), both treaty instruments in their official French consolidations — the 1994 convention with its 2004 and 2009 avenants and the 1978 succession and gift convention with its 2004 avenant, the authentic texts of both being French and English in equal authority — the administration's commentary (BOI-INT-CVB-USA series, including the 19 February 2020 update recording the IRS position on the CSG and CRDS and the IFI's place within the convention; fortune and elimination chapters of 2012–2015 vintage, read subject to the texts), and the case law of the Conseil d'État on the trust reporting regime and on the social levies of non-resident sellers (including CE, 31 March 2021, n° 436412). American law is stated at orientation level from secondary sources and is never load-bearing for a legal claim. Market data: DVF (DGFiP), villa sales ≥ €3M, estate-deduplicated, register through 2025-12-31. Ownership aggregates: compiled from public land and company registers, anonymised, as at 19 July 2026. Items flagged "at engagement" — communal rates, the deed-level gain base, the American return of credited taxes, the mapping of a particular trust onto the 1978 convention — are stated at mechanism level pending case-specific verification.

Qualification. This brief documents published law and public transaction data; it is research rather than personalised legal or tax advice, and individual circumstances — citizenship, residence history, matrimonial regime, the chain of title — change outcomes. For a live transaction, this office coordinates the appropriate French counsel (avocat fiscaliste, notaire) alongside the family's American advisers, and executes the property side.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

Further intelligence

The Riviera villa market — the coast-wide €3M+ index

Riviera property tax & relocation — the incoming buyer's primer

France–Netherlands — the convention pair

France–Poland — the convention pair