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AMERICANS IN FRANCE

What Americans in France need to know when moving back to the US

Looking to move back to the US from France? It might not be as straightforward as you imagine.

What Americans in France need to know when moving back to the US
A passenger walks past a welcome sign at the Los Angeles International Airport (LAX) (Photo by Patrick T. FALLON / AFP)

Moving countries is a time-consuming process – but if you’re American and living in France you might think that moving back to the US would be simpler?

Well, there won’t be a language barrier and as a US citizen you won’t need any immigration paperwork (although if you’re bringing a French partner with then that gets complicated) – but you will still face a fair share of administrative hurdles.

Here’s what to expect:

Can I drive on my French licence?

Most people living in France for over one year – excluding certain groups like students – are required to convert their US driver’s licence into a French one. That also means giving up your American licence.

READ MORE: Reader question: Do I have to swap my driving licence in France?

Once you get back to the United States, you may be able to drive with your French licence for a short period of time (usually a maximum of three months, depending on the state). You may also need to hold an ‘International Driver’s Permit’ (IDP) – if you do not hold an IDP, you can request one here

When it comes to switching your licence back to an American one, the steps will depend on the state and whether or not they hold a reciprocity agreement with France. If there is no agreement in place, you may have to take driving examinations again.

Several US States had licence swap agreements with France as of 2023, those with one star (*) allowed for swaps for Permis B licences in France, and those with two stars (**) allowed for swaps with Permis A and/or B licences in France.

The states were: Delaware*,  Maryland*, Ohio*, Pennsylvania**, Virginia*, South Carolina, Massachusetts,  New Hampshire, Illinois, Iowa, Michigan, Wisconsin*, Arkansas*, Oklahoma*, Texas*, Colorado*, Florida**, Connecticut**

The Permis A French licence is basically for motorbikes. Holders can ride two- or three-wheeled vehicles, with or without a sidecar.

The Permis B French driving licence allows holders to drive a vehicle with a maximum weight of 3.5 tonnes, which seats no more than nine people. This includes standard passenger cars, people carriers and minibuses.

Most states require a Social Security number and other documents like a valid ID (eg. passport) and proof of residence. 

Can I bring my French partner with me?

French nationals do not need a visa to spend less than 90 days the United States. However, before attempting to travel to the US, they must apply for the ESTA visa waiver, which is valid for up to two years. 

But if you want your French partner to spend more than 90 days in-country, then the subsequent administrative steps will depend on your relationship status. If you are dating or pacsé (in a civil partnership) in France, then you will not gain any special privileges in the eyes of US immigration authorities. 

For those who are married (including same-sex marriages) you can apply for the ‘Immigrant visa for a Spouse of a US Citizen’. To obtain this, you will need to submit Form I-130. The US State Department says on their website that “petitioners residing outside of the United States may file Form I-130, Petition for Alien Relative, online at https://www.uscis.gov or by mail to the USCIS Dallas Lockbox.”

When the form has been approved, either the American consulate or embassy will notify you. At this point, you will likely be called for an interview at the embassy.

Expect that the processing time could be several months (or even a year) and that you will likely need to show proof of your relationship.

As for engaged couples, you can apply for a K-1 visa – which means “you and your fiancé(e) intend to marry one another within 90 days of your fiancé(e)’s admission to the United States,” according to the State Department.

To qualify, you will need to file Form I-129F, which will ask USCIS to recognise the relationship between you and your fiancé(e).

Both of these processes can be time-consuming, it can help to join Facebook groups to get advice and hear others’ perspectives. You might consider joining either the group “Mariage Franco-Américain Formalités et Conseils” or “American Expats in Paris”.

Do I still have to pay French taxes? Any impact on my American taxes?

Generally, French tax declarations concern the previous year, so you will have to do at least one tax declaration and payment after moving back to the US.

In France, the annual tax declaration takes place in April, and concerns the previous calendar year. So if for example you move back to the US in September 2023, you will have to complete a tax declaration in April 2024, covering your 9 months of residency in France in 2023.

If you still own property in France you will pay property taxes there, and if you have any earnings in your former home you will likely still have to pay taxes there – check with your local French tax office. 

You will also need to inform the French taxman that you’re leaving the country, which you can do online by logging into your Personal area on the impots.gouv.fr website. 

As for any foreign income earned in France (ex. rental income), you must still report it to the IRS (Form 1040), even if you pay French tax on it. That being said, you could still be eligible for the Foreign Tax Credit to avoid paying tax twice. The same principle goes for declaring foreign bank accounts with over $10,000 – even if you have moved back to the US, this declaration (the FBAR) is still required.

When it comes to your American taxes, keep in mind that as a citizen filing from abroad, you were eligible for a two-month extension until June 15th each year. Once you move back to the US, you will have to file by April 15th. 

What about my pension contributions accrued in France?

If you have been working in France, you will probably have been contributing to the French pension system (unless you were a posted worker).

In France, you need a minimum of just one trimestre (quarter) of working and paying taxes in France to qualify for a French pension. The catch is that French pensions are based on contributions, so although you are eligible after just one trimestre, your pension will be pretty small. 

Americans living and working in France benefit from the Franco-American Social Security Agreement (SSA). Essentially, this allows Americans who have worked in France to have their pension calculated on a pro rata basis. 

READ MORE: Pensions: What should I expect if I worked in both France and a non-EU country?

The gist is that you will still benefit from some level of French pension, even if you move back to the United States. In fact, you would be able to qualify at age 64 for the French portion (ie before 67, which is the ‘full retirement age’ in the US for those born after 1960).

Technically, you should be able to receive the French portion of your pension into an American bank account – more info here.

When it comes to retiring in the US, you need 40 credits (ie 10 years of work in the US) to be eligible for social security benefits.

You can use this US government simulator to find out if you are eligible.

Do I need to hand back my residency card, health card etc before I leave France? 

Most countries require that you hand back residency cards before you leave, but in truth this is rarely strictly enforced. Check with the préfecture that issued your carte de séjour what they want you to do with them, but most préfectures simply ask you to mail it back. 

EXPLAINED: The bureaucratic boxes to tick if you plan to leave France permanently

If you do end up keeping residency or healthcare cards – don’t use them on trips back to the EU. Tempting as it might be to avoid long lines at the border or healthcare fees, you will create a confusing official record if you are claiming to be resident of two countries at once.

If you have received French citizenship, that is a different matter and of course you are entitled to keep and use your French passport when visiting the EU.

Keep in mind that US requires that dual nationals use their US passport when entering and leaving the country.

Can I keep my French bank account? Do I need a new US account? 

This one depends on the policy of your bank, but most banks in France require you to have a French address.

When you move back, you might have to open new US bank accounts, particularly if yours were closed. Americans living in France have experienced issues keeping their US-based checking accounts open due to their permanent residency having been in France, and many others have cited problems with brokerage accounts being closed on residency grounds. 

A practical option while you are moving and still have interests in both countries is to open an internet bank account with a company like Wise which offers accounts in both dollars and euros. You can use the Wise account to continue to pay any small payments or bills as they come in France. 

What about other financial considerations?

Think about your credit score, as this will become important again once you get back to the United States. If you have continued to make your payments on time and at the full amount, then you are probably in a good position. 

This is another area where you will need to consider your French partner, if you have one. They likely will not have a credit score, which could create issues in accessing affordable home and car insurance, as well as passing screenings for loans and apartment/ home rentals.

Additionally, it will not be possible for your French partner to open an American bank account until they have a valid Visa and address. You may need to budget for these delays while both of you are still in France.

As for financial considerations on the France side, be sure to close all accounts and subscriptions that you will no longer be using. Read the fine print as some account closures require the sending a lettre recommandée

Healthcare

If you are registered with the French healthcare system and have a carte vitale, you need to tell Assurance Maladie that you are leaving France. You can do so by filling out and sending in this form.

You might want to ask your French GP for your medical records, so that you can take them along to the United States. Keep in mind that medical records are not kept in a single file in France, instead you have an individual file with each professional you have seen. To request these files, you can ask in person or send a letter.

Once you get back to the United States, you will likely need to re-enroll in a health plan.

If you are planning to enroll in a health plan offered by your employer, be sure to ask when the open enrollment period will be so that you can plan accordingly.

You may be eligible for a plan with the ACA’s Health Insurance Marketplace, but keep in mind that the enrollment period for the following year starts on November 1st.

You can find more information here.

Will my EU/ French qualifications be recognised?

If you were studying or gaining professional qualifications while living in the EU, don’t assume that these will be recognised in the US. It’s a good idea to check if your qualifications will be recognised before you start job-hunting. 

For example, several fields, such as medicine, require lengthy processes for qualifications to be converted. If you were a teacher in France, you can check the teacher certification requirements by state here.

READ MORE: What are the rules on bringing cheese, meat and wine to the US from France?

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For members

PROPERTY

What restrictions are there on foreigners buying property in France?

Purchasing property in France as a foreigner has several extra hurdles - here's a look at some of the restrictions and other challenges you will want to be aware of beforehand.

What restrictions are there on foreigners buying property in France?

There are several things to consider before buying property in France. You may want to visit the area during different seasons to be sure that you enjoy it rain or shine, and you will want to consider how much you would end up paying in property taxes, as well as whether or not it will be a main residence or second home.

The law

Let’s start with the good news – there are no official rules in France against non French-citizens purchasing property, neither is there any requirement to be resident in the country in order to buy property – indeed foreign second-home owners make up a small but significant slice of the property market.

Revealed: Where in France do foreigners buy second homes

But in practice there are a number of challenges foreigners face when buying French property, especially if they need a mortgage.

Property sale process

Before making your decision, learn the steps to buying property in France and the expected timeline.

Roughly, there are five steps: making your offer, a cool-off period, signing a ‘Compromis de Vente‘, providing the notary (notaire) with your deposit, and signing the ‘Acte Authentique de Vente‘ (deed).

READ MORE: How long does it normally take in France to buy a property?

The French property purchase system is likely to be different to what you are used to – especially the role of the notaire.

Also Americans might be surprised to learn that in contrast to the US system of having a realtor who guides you through the entire process, in France – as in most of Europe – buyers are expected to do much work of the house-hunting work themselves.

Bureaucracy

There are a few extra steps added if you need a mortgage, but generally all foreign buyers should be prepared to have a valid ID (passport), as well as other documents including your marriage and/or divorce papers (to demonstrate your civil status).

At some point in the process, you will need to open a French bank account, even if that ends up just being for utilities after you’ve made the purchase. The earlier you can open a French bank account, the better.

You should know that purchasing property in France does not automatically give you residency rights. If you are not an EU citizen, then you will need a residency card or visa to spend extended time in France.

READ MORE: EXPLAINED: What type of French visa do you need?

Getting a mortgage

While there are no laws stopping foreigners from buying property in France for most people the biggest obstacle is getting a mortgage, as there are conditions that many foreigners cannot fulfil.

In France, the vast majority of loans are guaranteed by banks, and one bank’s offer to you may not be the same as another’s. You are free to contact several banks to find the best offer for your situation.

READ MORE: French property: How to get a mortgage in France

While there are alternative options besides banks, such as a ‘vendor loan’ (prêt vendeur) – where one sets up a credit contract directly with the seller of the property via a notary – this is much less common.

The biggest issue is that banks will require that foreigners prove that they will be able to legally remain in France for the entirety of the repayment period. As such, it can be very challenging those on short-term residency cards, to be accepted for a mortgage loan.

For the same reason, it is very difficult for non-residents to get a mortgage via a French bank.

Foreigners can also consider international options, or independent, specialised mortgage brokers, like those geared toward expats – however some have minimum income levels and minimum property purchase prices.

Another point to keep in mind is the fact that French banks also look favourably on ‘stable’ employment statuses, such as CDI (indefinite) work contracts, which, by their calculation, reduce risk of unemployment. It’s not impossible to get a mortgage if you are self-employed, but it’s harder.

Additionally, age can be a factor – lenders tend to be less likely to award mortgages to those nearing or above retirement age.

Americans – The situation is even more challenging for Americans in France, as banks can be reticent about working with Americans due to FATCA – which, according to the US dept of treasury, requires that “foreign financial institutions (FFIs) report to the IRS information about financial accounts held by US taxpayers, or by foreign entities in which U.S. taxpayers hold a substantial ownership interest.”

This has forces French banks to collect and maintain more information about their American customers. If the banks fail to disclose information to the IRS, they risk exclusion from the US market as well as penalties.

In a survey about the effects of citizenship-based taxation on Americans in France, one respondent said: “Multiple banks have denied me a mortgage because I am American.

“We used the services of a mortgage broker and when we went in for the final presentation a few weeks ago, only one out of the many banks queried offered us a mortgage, and it wasn’t even a good offer.”

READ MORE: Divorce, stress and fines: How citizenship-based taxation affects Americans in France

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