U.S. citizen in France: married to a u.s. citizen, filing jointly, virginia, ties kept
Combined marginal rate across this income: 15.8%. Rates are 2026 marginal rates after treaty credits, as an upper bound.
- Residence
- France, 5 full year(s)
- U.S. filing status
- Married filing jointly
- Income (all sources)
- 69,500 EUR ≈ $80,620
- U.S. ordinary marginal rate
- 12%
- U.S. qualified rate
- 0%
- NIIT exposed
- no
- U.S. state
- Virginia (ties kept)
- French tax shares
- 2
- French marginal rate (TMI)
- 30%
| Income | Amount | U.S. | State | France | Who taxes | Combined |
|---|---|---|---|---|---|---|
| Bank interest (local) | €500 | 12% | 5.8% | 31.4% | Residence first, U.S. credits | 37.1% |
| Dividends from U.S. companies | €1,500 | 0% | 5.8% | 31.4% | U.S. only | 5.8% |
| Dividends from local companies | €1,500 | 0% | 5.8% | 31.4% | Residence first, U.S. credits | 37.1% |
| Gains on shares sold | €6,000 | 0% | 5.8% | 31.4% | Residence first, U.S. credits | 37.1% |
| U.S. Social Security | €36,000 | 10.2% | — | — | U.S. only | 10.2% |
| 401(k) / IRA distributions | €24,000 | 12% | 5.8% | — | U.S. only | 17.8% |
Why each income is taxed this way
Bank interest (local) · 37.1% · France taxes first; the U.S. credits French tax, CSG/CRDS included.
- U.S.: Ordinary income, marginal 12%
- State: Virginia resident, up to 5.8%, no credit for foreign tax
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Virginia resident: state tax is added because states give no credit for foreign tax.
- Excess foreign credit carries forward 10 years (same category only).
US.WORLDWIDE · US.ORDINARY.2026 · STATE.RESIDENT · STATE.STICKY · FR.RESIDENT · FR.PFU.2026 · US-FR.SAVING · US-FR.ART24.RESOURCE · US.FTC
Dividends from U.S. companies · 5.8% · U.S. taxes; France gives a credit equal to its own tax.
- U.S.: Qualified dividends 0%
- State: Virginia resident, up to 5.8%, no credit for foreign tax
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Virginia resident: state tax is added because states give no credit for foreign tax.
US.WORLDWIDE · US.QUALIFIED.2026 · STATE.RESIDENT · STATE.STICKY · FR.RESIDENT · FR.PFU.2026 · US-FR.ART24.EQUALIZE
Dividends from local companies · 37.1% · France taxes first; the U.S. credits French tax, CSG/CRDS included.
- U.S.: Qualified dividends 0%
- State: Virginia resident, up to 5.8%, no credit for foreign tax
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Virginia resident: state tax is added because states give no credit for foreign tax.
US.WORLDWIDE · US.QUALIFIED.2026 · STATE.RESIDENT · STATE.STICKY · FR.RESIDENT · FR.PFU.2026 · US-FR.SAVING · US-FR.ART24.RESOURCE · US.FTC
Gains on shares sold · 37.1% · France taxes first; the U.S. credits French tax, CSG/CRDS included.
- U.S.: Long-term gains 0%
- State: Virginia resident, up to 5.8%, no credit for foreign tax
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Virginia resident: state tax is added because states give no credit for foreign tax.
US.WORLDWIDE · US.QUALIFIED.2026 · STATE.RESIDENT · STATE.STICKY · FR.RESIDENT · FR.PFU.2026 · US-FR.SAVING · US-FR.ART24.RESOURCE · US.FTC
U.S. Social Security · 10.2% · Taxable only in the United States (Article 18).
- U.S.: Up to 85% taxable at 12%
- State: Virginia: Social Security exempt
- France: Taxable only in the U.S.; counted for the rate on other income
US.WORLDWIDE · US.ORDINARY.2026 · US.SS.TAXABLE · STATE.RESIDENT · STATE.SS · FR.RESIDENT · US-FR.ART18.SS
401(k) / IRA distributions · 17.8% · Taxable only in the United States (Article 18).
- U.S.: Ordinary income at 12% (not subject to NIIT)
- State: Virginia resident, up to 5.8%, no credit for foreign tax
- France: Taxable only in the U.S.; counted for the rate on other income
- Virginia resident: state tax is added because states give no credit for foreign tax.
US.WORLDWIDE · US.ORDINARY.2026 · US.RETIREMENT · STATE.RESIDENT · STATE.STICKY · FR.RESIDENT · US-FR.ART18.PENSION
Forms to file
| IRS | Form 1040 | Every year, wherever you live (June 15 for filers abroad). |
| IRS | Form 1116 | Credit for French/UK tax, by category (general, passive). |
| IRS | FinCEN 114 (FBAR) | Foreign accounts ≈ $139,200, above $10,000. |
| State | Virginia resident return | Ties kept: the state can still tax you as a resident. |
| French tax office | 2042 | Annual French return for worldwide income. |
| French tax office | 2047 + 2042-C box 8TK | U.S.-source income: declared, then cancelled or reduced by the treaty credit. |
| French tax office | 3916-bis × 3 | Accounts outside France: U.S. bank account, U.S. brokerage, Interactive Brokers Ireland Ltd. |
Watch out for
Virginia can still tax you
Keeping ties makes you a likely Virginia resident: up to 5.8% on top, with no credit for foreign tax. Virginia can treat you as domiciled if you keep a home or ties there.
Rule trace (18 rules)
- US.WORLDWIDE — Citizenship-based taxation. U.S. citizens and green-card holders report worldwide income every year, wherever they live. (high, checked 2026-11-15 · IRS — U.S. citizens and resident aliens abroad (official))
- US.ORDINARY.2026 — 2026 ordinary income brackets. 10% to 37%. Single: 22% from $50,401, 24% from $105,701, 32% from $201,776. Joint: 22% from $100,801. (high, checked 2026-11-15 · IRS — Rev. Proc. 2025-32 (inflation adjustments for 2026) (official) · Tax Foundation — 2026 brackets (Rev. Proc. 2025-32))
- STATE.RESIDENT — State residency follows your ties. A state can keep taxing your worldwide income while you keep a home, licence or voter registration there. States rarely credit foreign tax. Xpat's reading Xpat's reading: Domicile is decided on facts, state by state. Xpat assumes the state taxes you as a resident whenever you say you kept ties, at its top rate. (medium, checked 2026-11-15 · Tax Foundation — state income tax rates 2026)
- STATE.STICKY — Sticky states. California, Virginia, New Mexico and South Carolina are known for treating former residents as still domiciled. Xpat's reading Xpat's reading: A practitioner's shortlist, not a legal category: these states audit departures more often. (medium, checked 2026-11-15)
- FR.RESIDENT — French tax residence. French residents are taxed on worldwide income and must declare it each spring (2042). (high, checked 2026-11-15 · impots.gouv.fr — Imposition des revenus de source étrangère (2047, 2074) (official))
- FR.PFU.2026 — Flat tax (PFU) 31.4%. Interest, dividends and share gains: 12.8% income tax + 18.6% social charges from 1 January 2026. (high, checked 2026-11-15 · economie.gouv.fr — PFU 31.4% from 2026 (official) · BOFiP — Prélèvement forfaitaire unique (CGI art. 200 A) (official))
- US-FR.SAVING — Saving clause. The U.S. keeps taxing its citizens as if the treaty did not exist, except where the treaty says otherwise. (high, checked 2026-11-15 · IRS — U.S.–France income tax convention (1994), text (official) · IRS — US–France treaty technical explanation (official))
- US-FR.ART24.RESOURCE — Article 24(2): re-sourcing. French-source income taxed by France: the U.S. credits the French tax (Form 1116). (high, checked 2026-11-15 · IRS — U.S.–France income tax convention (1994), text (official) · Hayot — France–US treaty Article 24)
- US.FTC — Foreign Tax Credit. Foreign income tax on foreign-source income is credited against U.S. tax (Form 1116), by category (general, passive). Excess credits carry forward 10 years. (high, checked 2026-11-15 · 26 U.S.C. §901 — foreign tax credit (official) · IRS — Instructions for Form 1116 (Foreign Tax Credit) (official))
- US.QUALIFIED.2026 — Qualified dividends and long-term gains. 0% / 15% / 20%. Single: 15% from $49,451, 20% from $545,501. Joint: 15% from $98,901, 20% from $613,701. (high, checked 2026-11-15 · IRS — Rev. Proc. 2025-32 (inflation adjustments for 2026) (official) · 26 U.S.C. §1 — tax rates, including capital gains rates in (h) (official))
- US-FR.ART24.EQUALIZE — Article 24(1)(b): credit equal to French tax. For U.S. citizens in France, U.S.-source dividends, interest and U.S. real-property income get a French credit equal to the French tax: only U.S. tax remains. (high, checked 2026-11-15 · IRS — U.S.–France income tax convention (1994), text (official) · IRS — US–France treaty technical explanation (official) · Hayot — France–US treaty Article 24)
- US.SS.TAXABLE — Social Security inclusion. Up to 85% of Social Security benefits are taxable at ordinary rates. (high, checked 2026-11-15 · 26 U.S.C. §86 — Social Security benefits (official))
- STATE.SS — Social Security and states. Most states exempt Social Security; in 2026 Colorado, Connecticut, Minnesota, Montana, New Mexico, Rhode Island, Utah and Vermont still tax some benefits. (medium, checked 2026-11-15)
- US-FR.ART18.SS — Article 18: U.S. Social Security. U.S. Social Security paid to a French resident is taxable only in the United States. (high, checked 2026-11-15 · IRS — U.S.–France income tax convention (1994), text (official) · US–France treaty Article 18 (pensions, Social Security))
- US.RETIREMENT — 401(k) / IRA distributions. Traditional account distributions are ordinary income; they are not investment income for the NIIT. (high, checked 2026-11-15 · 26 U.S.C. §1411 — net investment income tax (official))
- US-FR.ART18.PENSION — Article 18: U.S. pensions and IRAs. Distributions from U.S. plans (401(k), IRA) to a French resident are taxable only in the U.S.; France counts them for the rate on other income. Xpat's reading Xpat's reading: Read from Article 18 as amended by the 2004 protocol. Roth accounts and lump sums can be treated differently: check with an adviser. (medium, checked 2026-11-15 · IRS — U.S.–France income tax convention (1994), text (official) · US–France treaty Article 18 (pensions, Social Security))
- US.FBAR — FBAR (FinCEN 114). Foreign financial accounts above $10,000 in total at any time. (high, checked 2026-11-15 · FinCEN — Report of Foreign Bank and Financial Accounts (FBAR) (official))
- FR.3916 — Foreign accounts (3916-bis). Every account outside France (U.S. bank, brokerage, IRA custodian) is declared each year. €1,500 fine per account. (high, checked 2026-11-15 · impots.gouv.fr — declaring foreign accounts (3916) (official) · Service-Public.fr — Déclarer ses comptes à l'étranger (3916 / 3916 bis) (official))