France–United States — Tax Treaty

1Two conventions, in force and unamended since 2009 — and the clause that outranks them both

Two instruments govern this pair. 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, 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 reaches lifetime gifts and the American generation-skipping transfer tax as well as estates. The multilateral instrument (the anti-abuse rule agreed internationally in 2017) modifies neither — the United States has not signed it. Both conventions were done in French and English, the two texts equally authentic; this brief quotes the French consolidations.

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 value in a family's 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 — the saving clause of article 29 §2 (1994) and its estate-side counterpart, article 1 §4 (1978): 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 consequence runs through every section of this brief: for a US citizen the conventions do not exempt, they organise credits.

On the American side, this brief states the law at orientation level only: 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 kinship 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 — § 3 prices that meeting. The verified ground of this brief is the French side and the two conventions; the American reading belongs with the family's US counsel.

Sources considered: 1994 convention arts. 2, 4, 29 §2, 30; 1978 convention arts. 1 §4, 2, 4 §3; BOI-INT-CVB-USA (19 February 2020 update; older chapters — the text prevails). Scope note: treaty texts prevail over commentary; both instruments re-checked at this edition. American law is stated for orientation only.

Reviewed as at 10 August 2026 · 1994 convention arts. 2, 4, 29 §§1–3, 30; 1978 convention arts. 1, 2, 4; BOI-INT-CVB-USA (2020 update)

2What you pay to buy a property in France, and what it costs you every year

The purchase follows the standard French sequence: offer, pre-sales contract (compromis de vente) with a ten-day cooling-off period, customarily a 10% deposit, conditions precedent, then the deed (acte authentique) before the notaire, who collects the duties and registers title. The notaire is a public officer, not the buyer's counsel; American buyers typically retain their own advisers on both sides of the Atlantic, because the vehicle chosen at the deed has United States consequences of its own. The structure questions of § 3 — the trust above all — deserve answers before the compromis is signed.

Worked example — the median Cannes villa (€4.9M, the DVF median of Cannes and its hills):

The notaire itemises duties and émoluments precisely on the actual deed; a new-build VAT regime, furniture carve-outs or mortgage security change the arithmetic. The figures reflect the published scales and are stated for orientation.

The wealth tax — treaty-confirmed, never doubled

Article 964 of the tax code charges an annual tax on real-estate wealth (IFI) above €1,300,000 of taxable assets. For an owner not domiciled in France the base is French property plus the property fraction of any company's shares (article 965, 2°) — and here 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 reads the IFI into the convention through the analogous-tax clause of article 2 §2. Interests in entities other than companies — a trust among them — follow the same rule where their value derives from French real estate (article 23 §1 c). The United States levies no federal wealth tax, so the charge is single.

For a 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 a US citizen without French nationality the same five-year exclusion of non-French assets as a treaty right — one France cannot narrow unilaterally — renewable where the person, having ceased to be a French resident for at least three years, later returns. Under the worldwide ISF that 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 property itself: French real estate stood outside both shelters in every era.

Recurring charges follow the property: the annual local property tax (taxe foncière) at communal rates; for furnished second homes in designated high-demand areas (zone tendue) — the marquee Riviera communes among them — a possible surcharge (surtaxe) voted by the commune; and the annual occupancy declaration required of all owners. These rates are communal and year-specific; this brief re-verifies them at each edition. The American counterpart is stated once and stands for every section: a US citizen or resident reports the property's events — rental income when let, gain when sold — on the federal return, with the credit machinery of article 24 doing the ordering.

Our agency prepares a free valuation for owners at valuation.elenaagueeva.com. An agent contacts you within 48 hours to arrange a visit.

It rests on the same official records a French property valuer (expert immobilier) works from: the government's register of recorded sale prices, the cadastre, and the planning permits granted on the parcel. The agent then visits to appraise the view, the garden, and the quality of the construction and the finishes. The valuation report (avis de valeur) is produced within 48 hours of the visit.

The same figure carries your French filings. Wealth tax, the 3% company tax and gift duty are all declared at the property's market value. The law takes that value from your own detailed estimate (articles 761 and 973 of the tax code), and asks no particular valuer to produce it. A court-appointed expert (expert judiciaire) belongs to litigation, not to a declaration. If the administration challenges your figure, a dated, written valuation resting on comparable sales is what supports it.

The first valuation of a property is free for its owner or seller. A repeat valuation of the same property, or one commissioned by a family office, a bank or another adviser for a client, is a billable engagement — ask us for terms.

Sources considered: CGI arts. 964 (incl. 1°, al. 2), 965, 1418; 1994 convention arts. 2 §2, 23 §§1, 1 c, 6, 24. Scope note: costs follow the published scales and are itemised on your deed; communal rates are re-checked at each edition.

Reviewed as at 10 August 2026 · CGI arts. 964–965; 1994 convention arts. 2 §2, 23 §§1, 6

3Five ways to own a French property, and what follows from each

A holding vehicle answers seven questions, of which tax is one, and rarely the decisive one.

For an American buyer the analysis carries one organising fact: instruments that are ordinary in the United States — 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 given it a statute of its own — three texts 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 property satisfies the condition by itself — must declare the trust's constitution, terms, modifications and extinction, and file annual valuations (article 1649 AB); the Conseil d'État has upheld the penalty regime attached to the obligation. Second, the wealth side: trust assets within the IFI's scope are included in the settlor's taxable estate, or in that of a beneficiary treated as the 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, not an extra cost for the compliant. Third, transmissions: where a transfer through a trust can be qualified as an ordinary gift or succession, 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 in the United States, answers to an entirely different regime once a French property 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 — France taxes the property because it stands in France (article 5) — and how a particular trust's transmissions map onto the treaty is examined with counsel on both sides when our agency takes the file.

Borrowing against the property — 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 the liquidity stays invested while the debt reduces the taxable base. The mechanics are lawful and the code expects them. Acquisition debt owed to a bank is deductible from the IFI base (article 974), and financial assets sit outside that base. Three limits apply. A loan repaying capital only at term is treated as if it were being repaid gradually, the deduction declining over the loan's life — 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 mainly for tax. And the debt must be real — actually drawn, actually serviced, at market terms; routed through an SCI's shareholder account it no longer reduces the taxable value of the shares (article 973). The 1978 convention adds a succession counterpart: debts are deducted from the taxable estate in the proportion the assets taxable in each state bear to the whole (article 9). On this pair one more line belongs in every financing memo: interest deductibility, currency and the US treatment of the same borrowing rarely align — a facility that improves the French position can worsen the American one, so the two are modelled together or not at all, with the lender and the French tax lawyer, before the offer.

Sources considered: CGI arts. 965, 970, 973–974, 990 J, 1649 AB, 792-0 bis; 1994 convention arts. 13 §2, 23 §1 c; 1978 convention arts. 5, 9. Scope note: structures are questions for analysis, not recommendations; whether a US trust or LLC counts as an owner for French purposes is a question of fact and instrument on which no general answer can be given here.

Reviewed as at 10 August 2026 · CGI arts. 965, 970, 973–974, 990 J, 1649 AB, 792-0 bis; CE trust decisions read

4What you pay when you sell

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 shrinks by 6% for each year of ownership beyond the fifth and 4% for the twenty-second (article 150 VC), the 19% income-tax component (article 200 B) extinguishing after 22 years. Taxable gains above €50,000 bear the progressive surcharge of article 1609 nonies G, which reaches 6% at the prices this market transacts.

Worked example — the duration clock, per €1,000,000 of gross gain:

Two features distinguish the American seller's file from a European one. The United States sits outside the EU and the EEA, so the seller must in principle appoint an accredited tax representative (représentant fiscal), who signs the gain computation and answers for it — dispensed automatically where the price does not exceed €150,000 per seller or where the duration allowances have extinguished both tax and levies, thresholds a Riviera sale rarely meets. And the social levies apply at their full rate until the thirtieth year: the reduced 7.5% lane 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 way around them (31 March 2021, n° 436412). One American mechanism then softens what the French computation has hardened: since July 2019 the Internal Revenue Service recognises the CSG and CRDS as creditable taxes within the 1994 convention — recorded by the French administration in its 2020 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 — the saving clause keeps its citizens and residents within the American base — and the treaty answers with the credit of article 24 §2; 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. A French gain computed on a duration-abated base and a US gain measured from a different starting point in a different currency are not two calculations of the same number: the credit that reconciles them is granted on each state's own rules and can leave a residue that neither system regards as its problem — run on the family's actual basis when our agency takes the file. Selling the shares of a property-rich company instead of the property changes the buyer pool, the French analysis and the American one; that choice belongs before marketing begins.

If you leave France after selling: the exit tax

The charge is narrower than its name suggests. France's exit tax (article 167 bis) reaches only people domiciled in France for six of the ten years before departure, and only their unrealised gains on securities — above €800,000, or holdings of 50% or more of a company's profits. A property already sold has settled its own tax under the regimes above, and the proceeds are not within the charge. Shares of a family SCI kept under the ordinary income-tax regime stay within the real-estate regime (article 150 UB) and outside the exit tax; a company that has opted for corporation tax changes the classification, and the option belongs on any pre-departure checklist. Where the charge does apply, payment is generally deferred, and the assessment lapses where the securities are still held two years after departure — five where the portfolio exceeded €2.57M — or upon return to France.

Sources considered: 1994 convention arts. 13 §2 a, 24 §§1–2, 29 §2; CE n° 436412; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 235 ter, 244 bis A, 1609 nonies G; BOI-RFPI-PVINR-30-20; BOI-INT-CVB-USA-10 (IRS 2019 recognition). Scope note: allowances follow the statutory scales; the base is itemised on the deed.

Reviewed as at 10 August 2026 · 1994 convention arts. 13, 24, 29 §2; CE n° 436412; CGI arts. 150 VC, 200 B, 244 bis A, 1609 nonies G

5Renting before you buy, and renting your property out

Renting before you buy

A rental year before purchase remains the classic first step, with one caution stated plainly: French tax domicile (article 4 B) turns on the location of your household, your main place of stay and the centre of your professional and economic interests — none of which defers to a lease. A Riviera property that becomes the family's effective home can establish French residence before any purchase — and 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 credits of article 24 organise the overlap. The five-year clauses of articles 23 §6 and 4 §3 then give the calendar of those first years a value of its own. The choice between furnished seasonal rentals and the one-to-three-year civil lease sets your exit flexibility; match it to the trial's real purpose.

Renting your property out

French-source rent of a non-resident — furnished rentals included — is taxed at a minimum of 20% up to the second-bracket ceiling and 30% above it, unless you demonstrate a lower worldwide effective rate (article 197 A); the social levies apply in addition, at the full rate for American affiliation, as for the sale above. The convention assigns the income to France as the state where the property stands (article 6 §1) and permits a net-basis election where domestic law does not already provide one (article 6 §6) — French law does, the furnished regimes computing rental income net of charges or of a standard allowance, itemised when our agency takes the file. 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 on the rents sharing, since 2019, in the creditable-tax recognition of § 4.

Sources considered: CGI arts. 4 B, 197 A, 235 ter; 1994 convention arts. 4, 6 §§1, 6, 23 §6, 24 §2, 29 §2. Scope note: treatment turns on the form of exploitation and on affiliation, both questions of fact.

Reviewed as at 10 August 2026 · CGI arts. 4 B, 197 A; 1994 convention arts. 6, 24 §2, 29 §2

6What happens to the property when you die, or give it away — inside one of France's few succession treaties

The 1978 convention governs succession duty and gift duty alike, a reach most French succession treaties lack. Its architecture is settled. France taxes the property 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 assets located in France (article 12 §2 b), and for a US citizen domiciled in France it credits the French tax across the estate.

The 2004 avenant 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 article 779 and the spouse's succession exemption apply to the property whichever side of the Atlantic the family lives on, ahead of the scale of article 777, progressive to 45% in the direct line. Claims under the convention are made within five years (article 13).

Testamentary freedom meets the reserved share

Before either state determines the duty, the civil law determines who inherits, and here the pair 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 an EU national or habitual resident and the applicable foreign law allows no reserved-share mechanism for children, each child may take a compensatory levy on assets situated in France — the property first among them — up to the French reserved share (Code civil, article 913, al. 3). A French property is the asset on which the two traditions meet; the will, the matrimonial regime carried into the purchase and the calendar of any gifts belong with counsel on both sides, 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.

Giving your children the ownership now, and keeping the use for life (démembrement)

The structure commonly proposed alongside the loan divides ownership itself: you keep the usufruct — the use of the property and its income for life — and gift the bare ownership to the next generation. The code values the split by age: bare ownership is worth 60% of full value where the usufruct holder is between 61 and 70, and 70% between 71 and 80 (article 669); the gift bears duty on that fraction alone, at today's value, and the reunification at death is not a further taxable transmission. Article 751 sets the conditions — a notarised gift, made more than three months before death, valued on the article 669 scale — and article 968 keeps the full value in your own IFI base: your wealth tax does not move. Because the 1978 convention covers gifts, the transfer stays inside the treaty's division and credit machinery — an advantage most pairs in this collection lack, worth using deliberately rather than discovering late; its American gift-tax counterpart is a counsel question.

Sources considered: 1978 convention arts. 2, 5, 8, 9, 11 §3, 12 §§2–4, 13; CGI arts. 669, 751, 777, 779, 968; Code civil arts. 912, 913 al. 3; EU Regulation 650/2012. Scope note: the American estate and gift regime is stated for orientation; QDOT and election mechanics are named only via the treaty's own text.

Reviewed as at 10 August 2026 · 1978 convention arts. 2, 5, 8, 11, 12, 13; CGI arts. 669, 751, 777, 779; Code civil art. 913; EU Reg. 650/2012

7The eight questions American owners ask most

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

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

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

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

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

France first, where the property stands (article 13), under article 244 bis A with the duration allowances — the income-tax component extinguishing after 22 years and the levies after 30. The United States then taxes the same gain under its citizen and residence rules and credits the French tax (article 24 §2); since 2019 the IRS also treats the CSG and CRDS as creditable taxes. The accredited-representative requirement of § 4 applies, the United States sitting outside the EU and the EEA.

Do American sellers pay the full French social levies?

Yes. The reduced 7.5% lane rests on the European coordination regulation and does not reach American affiliation; the Conseil d'État confirmed the full charge on a US resident's sale and rejected the free-movement-of-capital argument (31 March 2021, n° 436412). The softener is American: the IRS treats the CSG and CRDS as creditable convention taxes, so the largest part enters the US foreign-tax credit rather than being lost.

Which country taxes the succession on a French property?

France, because the property stands there (1978 convention, article 5), with property-rich shares treated as the real estate itself. The United States, taxing its citizens and domiciliaries, credits the French duty (article 12); France grants a US-domiciled deceased's estate the same allowances as if French-domiciled (article 12 §4); and the 2004 avenant added a treaty marital deduction for non-citizen spouses (article 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 (article 2): a gift of the property, or of its bare ownership, is taxed by France because the property stands there, with the treaty deciding who taxes what and what each side credits, and 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 (article 1649 AB). Trust assets within the IFI's scope are taxed in the settlor's hands (article 970); the 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 reaching 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 their 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 property first among them (Code civil, article 913, al. 3).

Sources considered: 1994 convention arts. 13, 23 §§1, 6, 24 §2, 29 §2; 1978 convention arts. 2, 5, 11 §3, 12; CGI arts. 964, 970, 990 J, 1649 AB, 792-0 bis, 244 bis A; CE n° 436412; Code civil art. 913; EU Regulation 650/2012. Scope note: these answers condense the sections above and inherit their scope notes.

Reviewed as at 10 August 2026

8The court decisions, the sources and the sales figures

The decisions read for this brief

CE, 31 March 2021, n° 436412 — the social levies apply in full to a United States resident's sale; the free movement of capital offers no way around them (the Jahin line applied to this pair). CE, 13 October 2016, n° 402318 and 5 March 2018, n° 404554/405025 — the trust-reporting regime of article 1649 AB and its penalties stand. CE, 25 September 2017 and 7 February 2018, n° 412024 — the article 990 J levy operates as the backstop of the reporting, not beside it.

What changed, and what our agency is watching

The instruments stand as amended — 1994 with its 2004 and 2009 avenants, 1978 with its 2004 avenant — and neither is touched by the multilateral instrument, which the United States has not signed. The most recent movement is administrative: the IRS recognition, in July 2019, of the CSG and CRDS as creditable taxes, recorded by the French administration on 19 February 2020 — the same commentary that reads the IFI into the 1994 convention. Watch items for the next edition: annual finance-law movements on the IFI and transfer duties; communal surcharge votes on the Riviera arc; the calendar of the American estate-tax exclusion, which American families plan against; and any refresh of the 2012–2015-vintage fortune and elimination chapters, which this brief reads subject to the treaty texts. The authentic texts of both conventions are French and English, equally authoritative; the corpus holds the French official consolidations at statutory force, and the English authentic texts are not yet held — an open item our agency records rather than leaves implicit.

The sales figures behind this brief

Seen from the United States, the Riviera's €3M+ villa market leads with Cannes. Cannes and its hills — the Super Cannes quarter included — contributed 306 villa sales of €3M and above for €2,066M, at a €4.9M median and a €46.5M ceiling. The Saint-Tropez peninsula remains the largest €3M+ register on the coast, at 1,006 sales for €7,049M; Saint-Jean-Cap-Ferrat is its narrowest and most expensive, at 178 sales for €2,375M, a €6.5M median and a €200.0M ceiling.

Source: DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales ≥ €3M, 2014–2025, duplicate estate records removed — the same method as the published Riviera Intelligence pages. Register complete to 31 December 2025. Across the 20 Riviera communes studied, American residence appears at roughly 2% of foreign-held ownership positions — a presence the register records only faintly: the families this brief concerns are, for the most part, buyers the coming decade will record. Aggregates only; no individual holding is identified.

How this brief was checked, and its limits

Legal statements are verified against the Chiron Legal Corpus and re-checked against the official sources at each edition. The review of 10 August 2026 covered the consolidated CGI and Code civil articles cited, both conventions in their official French consolidations at statutory force, the administration's commentary (the 2020 update recording the IRS position and the IFI's place; the 2012–2015 fortune and elimination chapters read subject to the texts), and the Conseil d'État decisions above. American federal and state law — the citizenship basis, the estate and gift regime, the foreign tax credit, the treatment of trusts and LLCs — is stated at orientation level only and is never load-bearing for a legal claim; whether a particular trust or LLC counts as an owner for French purposes is a question of fact and instrument on which no general answer can be given here. Items that depend on the file — communal rates, the deed-level gain base, the American return of credited taxes, the mapping of a trust onto the 1978 convention — are stated at mechanism level and verified case by case. Market data: DVF (DGFiP), villa sales ≥ €3M, duplicate estate records removed, register complete to 31 December 2025.

This brief sets out published law and public transaction data. It is research, not advice on your own situation: your citizenship, residence history, matrimonial regime and chain of title all change the answer. For an actual purchase or sale, our agency coordinates the French tax lawyer and the notaire alongside the family's American advisers, and handles the sale or purchase itself.

Sources considered: CE n° 402318, n° 404554, n° 405025, n° 412024, n° 436412; BOI-INT-CVB-USA; both conventions' final clauses. Scope note: decision texts read; DVF register, duplicate estate records removed.

Reviewed as at 10 August 2026 · decision texts read; DVF register, duplicate estate records removed

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