American buyers are the largest non-resident segment of the French market, drawn to Paris, Provence, the French Riviera and the Alps. The purchase process is secure and well defined, but it follows a notarial logic that differs sharply from a US closing.
What sets the United States apart is citizenship: a US citizen or green card holder remains taxable in the United States on worldwide income, wherever they live. The France United States tax treaty prevents double taxation, but it means reasoning across two systems at once. Some common French structures, such as the SCI or French life insurance, can be counterproductive for a US person.
French Realty prepares and coordinates every step on the French side and connects you with partners experienced in French American matters. We inform and guide: the notarial deed and personalised tax advice remain the responsibility of our partners.
Worldwide US taxation stays: you plan across two tax systems
Loans and bank accounts are harder for a US person (FATCA)
French SCI and life insurance are often ill-suited to US persons
Inheritance: French forced heirship versus US testamentary freedom
The purchase process seen from the United States
A single notaire secures the sale and registers title. You can sign remotely, without travelling to France.
What changes for you
The purchase goes through a notaire, a public officer who authenticates the sale and registers title, whereas the United States relies on a title company and escrow.
You first sign a preliminary contract (compromis or promesse), with a ten day cooling off period for the buyer, then the final deed two to three months later.
Time difference and distance are handled with a notarised power of attorney: a representative signs for you in France.
Points to watch
Allow several weeks for a power of attorney that is apostilled and translated.
The deposit (5 to 10 % of the price) is paid at the compromis stage, into the notaire's escrow account.
Plan for the timing and cost of an international transfer and for the dollar to euro conversion.
How French Realty supports you Partner notaire
We coordinate the practical side end to end (appointments, surveys, inventory, key handover, utilities) and connect you with a partner notaire used to American buyers. The deed itself remains the notaire's work.
A loan is still possible but rarer for a US person, and opening a French account has become a topic in itself.
What changes for you
Many French banks restrict lending and account opening for US persons, because of FATCA and US regulatory constraints.
For a non-resident, the required down payment is usually higher (often at least 20 to 30 %) and borrower's insurance is required.
Many American buyers pay cash, which simplifies the timeline but shifts the focus to currency exchange and fund transfers.
Points to watch
Lock in the exchange rate: a dollar to euro swing can cost more than the acquisition fees.
Open an account as early as possible: the US person issue lengthens the process.
Compare a euro loan with a cash purchase depending on your dollar exposure.
How French Realty supports you Partner broker
We point you to a partner broker specialised in non-resident borrowers and US persons, and to suitable currency solutions. French Realty does not provide credit: we prepare the file and ease the introduction.
Your French rental income is taxed in France, then accounted for in the United States; the treaty prevents double taxation.
What changes for you
French source rental income is taxed in France, with a minimum 20 % rate for non-residents, unless you can show a lower average rate.
Above 1.3 million euros of net French real estate, the property wealth tax (IFI) applies, even while resident in the United States.
The France United States treaty grants a US tax credit to neutralise double taxation, but the IRS filing is still required.
Points to watch
The annual property tax is owed by the owner; a second home may also incur a residence tax.
Keep clear rental accounts: they serve both sides of the Atlantic.
The tax calendar and the exchange rates used differ between France and the IRS.
How French Realty supports you Partner tax lawyer
We coordinate day to day management and providers, then connect you with a partner tax lawyer who masters the France United States treaty. Personalised tax advice rests with that partner.
Resale: capital gains and tax representative
As a non-EU resident, you fall under the non-resident capital gains regime and often must appoint an accredited tax representative.
What changes for you
Non-resident capital gains are taxed in France at 19 %, plus social levies, with allowances for the length of ownership.
Full exemption is reached after 22 years of ownership for income tax and 30 years for social levies.
Above 150,000 euros of sale price, a non-EU resident must generally appoint an accredited tax representative, subject to exemption cases.
Points to watch
The cost of the accredited tax representative (often a percentage of the price) should be budgeted from the moment you list.
The French gain must also be reported in the United States, applying the treaty.
Keep renovation invoices: they raise the acquisition cost used and reduce the taxable gain.
How French Realty supports you Partner tax lawyer
We prepare the sale file and the practical side, and point you to a partner notaire and accredited tax representative. The regulated transaction and the tax guarantee are carried by those partners.
As a US resident, you do not benefit from the exemption reserved for those affiliated to a European scheme: the levies apply at the full rate.
What changes for you
French source rental income and real estate gains bear social levies of 17.2 %.
The exemption from CSG and CRDS, open to those affiliated to another EU state's social security, does not apply to a US resident.
These levies come on top of income tax and capital gains, and feed the US tax credit calculation.
Points to watch
Factor 17.2 % of social levies into your rental yield projections from the outset.
The matter is technical: how it interacts with US taxation deserves dedicated advice.
How French Realty supports you Partner tax lawyer
We point you to a partner tax lawyer to secure how French levies interact with your US filing.
Inheritance: forced heirship and US trusts
Property located in France falls under French inheritance law, which reserves a share for children, whereas US law allows broad testamentary freedom.
What changes for you
French forced heirship protects children: you cannot freely disinherit, unlike common US practice.
The EU succession regulation lets you choose your national law by will, but a 2021 French law may restore a compensatory claim for reserved heirs.
US trusts are recognised cautiously under French law and can trigger heavy taxation: their treatment must be anticipated.
Points to watch
A France United States estate and gift tax treaty exists to avoid double taxation, but does not govern civil devolution.
Have the consistency between your US will and the fate of the French asset checked.
French life insurance, often used to pass on wealth, is delicate for a US person.
How French Realty supports you Partner notaire
We connect you with a partner notaire and, if needed, a lawyer in international succession. Drafting deeds and succession advice are theirs.
Stays: the Schengen rule and the long stay visa
Without a visa, you are limited to 90 days in any 180 in the Schengen area. A longer stay requires a long stay visa.
What changes for you
A US citizen travels without a visa but cannot exceed 90 days in any 180 day period in the Schengen area.
To enjoy your property more, the long stay visitor visa allows staying beyond that limit.
A lasting move may make you a French tax resident, without erasing your US obligations.
Points to watch
Count your Schengen days across the whole area, not only in France.
The long stay visa requires proof of resources and health cover.
How French Realty supports you
We ease the practical side of your stay and point you to the right contacts for visa steps. French Realty does not handle consular formalities.
Structuring: why an SCI is risky for an American
The SCI, popular in France to hold and pass on property, can create heavy tax complexity for a US person.
What changes for you
The US authorities may reclassify an SCI (as a corporation or partnership), with extra filings and a risk of double taxation.
Direct ownership is often simpler for a US person, but leaves French forced heirship fully in play.
Investments held inside certain structures may fall under the US PFIC regime, which is especially punitive.
Points to watch
Do not set up an SCI by default: for a US person, the decision must come before the purchase.
Any French American wealth structure needs advice on both sides at once.
How French Realty supports you Partner tax lawyer
We point you to a partner French American tax lawyer and a notaire to decide the ownership form before buying. The structure itself rests with those partners.
No. A notarised power of attorney lets you sign the compromis and the final deed remotely. We coordinate everything from France.
Is an SCI a good idea for an American?
Often no. It can trigger heavy US filings and taxation. The decision should be made with a tax lawyer before buying.
Is double taxation avoided?
The France United States treaty generally neutralises double taxation through a tax credit, but filings remain due in both countries.
Our role, made clear
This guide is informational and is not personalised advice. French Realty informs, prepares and coordinates; regulated acts (transactions, tax or legal advice, notarial deeds) are carried out by qualified partners under their own responsibility. Have your situation validated by a professional.
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