U.S. citizen in France: married to a non-u.s. spouse, filing separately, missouri, ties kept
Combined marginal rate across this income: 34.3%. Rates are 2026 marginal rates after treaty credits, as an upper bound.
- Residence
- France, 5 full year(s)
- U.S. filing status
- Married filing separately
- Income (all sources)
- 99,500 EUR ≈ $115,420
- U.S. ordinary marginal rate
- 22%
- U.S. qualified rate
- 15%
- NIIT exposed
- no
- U.S. state
- Missouri (ties kept)
- French tax shares
- 2
- French marginal rate (TMI)
- 30%
| Income | Amount | U.S. | State | France | Who taxes | Combined |
|---|---|---|---|---|---|---|
| Salary | €90,000 | 22% | 4.7% | 30% | Residence first, U.S. credits | 34.7% |
| Bank interest (local) | €500 | 22% | 4.7% | 31.4% | Residence first, U.S. credits | 36.1% |
| Dividends from U.S. companies | €1,500 | 15% | 4.7% | 31.4% | U.S. only | 19.7% |
| Dividends from local companies | €1,500 | 15% | 4.7% | 31.4% | Residence first, U.S. credits | 36.1% |
| Gains on shares sold | €6,000 | 15% | — | 31.4% | Residence first, U.S. credits | 31.4% |
Why each income is taxed this way
Salary · 34.7% · Taxed where you work; the U.S. credits that tax (FTC). The FEIE is the alternative.
- U.S.: Ordinary income, marginal 22%
- State: Missouri resident, up to 4.7%, no credit for foreign tax
- France: Income scale, marginal 30% (2 shares) · social contributions: ≈22% employee social contributions
- Missouri 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 · US.STACKING · STATE.RESIDENT · FR.RESIDENT · FR.BAREME.2026 · FR.SOCIAL.WAGES · US-FR.SAVING · US-FR.ART24.RESOURCE · US.FTC · US.FEIE.2026
Bank interest (local) · 36.1% · France taxes first; the U.S. credits French tax, CSG/CRDS included.
- U.S.: Ordinary income, marginal 22%
- State: Missouri resident, up to 4.7%, no credit for foreign tax
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Missouri 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 · FR.RESIDENT · FR.PFU.2026 · US-FR.SAVING · US-FR.ART24.RESOURCE · US.FTC
Dividends from U.S. companies · 19.7% · U.S. taxes; France gives a credit equal to its own tax.
- U.S.: Qualified dividends 15%
- State: Missouri resident, up to 4.7%, no credit for foreign tax
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Missouri resident: state tax is added because states give no credit for foreign tax.
US.WORLDWIDE · US.QUALIFIED.2026 · STATE.RESIDENT · FR.RESIDENT · FR.PFU.2026 · US-FR.ART24.EQUALIZE
Dividends from local companies · 36.1% · France taxes first; the U.S. credits French tax, CSG/CRDS included.
- U.S.: Qualified dividends 15%
- State: Missouri resident, up to 4.7%, no credit for foreign tax
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Missouri 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.QUALIFIED.2026 · STATE.RESIDENT · FR.RESIDENT · FR.PFU.2026 · US-FR.SAVING · US-FR.ART24.RESOURCE · US.FTC
Gains on shares sold · 31.4% · France taxes first; the U.S. credits French tax, CSG/CRDS included.
- U.S.: Long-term gains 15%
- State: Missouri: capital gains exempt
- France: Flat tax (PFU) 31.4% = 12.8% + 18.6% social charges
- Excess foreign credit carries forward 10 years (same category only).
US.WORLDWIDE · US.QUALIFIED.2026 · STATE.RESIDENT · STATE.MO.GAINS · FR.RESIDENT · FR.PFU.2026 · US-FR.SAVING · US-FR.ART24.RESOURCE · US.FTC
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 | Missouri 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
Missouri can still tax you
Keeping ties makes you a likely Missouri resident: up to 4.7% on top, with no credit for foreign tax. Since tax year 2025 Missouri subtracts 100% of capital gains reported on the federal return.
Non-U.S. spouse
Filing separately keeps your spouse's income and accounts out of the U.S. system; joint filing needs an election and brings in their worldwide income.
One social security system
Totalization agreements mean you pay social contributions where you work, not U.S. FICA or self-employment tax (keep a certificate of coverage if self-employed).
Rule trace (19 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))
- US.STACKING — FEIE stacking rule. Income excluded with the FEIE still sets the rate on the rest of your income. (medium, checked 2026-11-15 · 26 U.S.C. §911 — foreign earned income exclusion, stacking in (f) (official))
- 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)
- 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.BAREME.2026 — Income tax scale 2026. Per tax share: 0% to €11,600, 11% to €29,579, 30% to €84,577, 41% to €181,917, then 45%. Couples get 2 shares; +0.5 per child for the first two, +1 from the third. Set by the finance law for 2026 (loi n° 2026-103 of 19 February 2026, CGI art. 197) for income earned in 2025. Xpat's reading Xpat's reading: The scale for income earned in 2026 will be set by the finance law for 2027, expected around December 2026. Until then Xpat applies the scale voted for 2025 income; thresholds usually rise by about 1% a year. (high, checked 2026-11-15 · BOFiP — Indexation du barème de l'impôt sur le revenu, revenus 2025 (loi n° 2026-103, art. 4) (official) · Service-Public.fr — Impôt sur le revenu : tranches et taux d'imposition 2026 (official) · Barème IR 2026 (revenus 2025))
- FR.SOCIAL.WAGES — Social contributions on wages. About 22% employee contributions, including 9.7% CSG/CRDS, which the IRS accepts as creditable since 2019. Xpat's reading Xpat's reading: 22% is an average for employees; the real rate depends on salary level and status. (medium, checked 2026-11-15 · CSG/CRDS creditable since 2019)
- 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.FEIE.2026 — Foreign Earned Income Exclusion. Up to $132,900 of foreign wages or self-employment income excluded in 2026 (Form 2555). Not available for pensions or investment income. (high, checked 2026-11-15 · IRS — Rev. Proc. 2025-32 (inflation adjustments for 2026) (official) · IRS — Instructions for Form 2555 (Foreign Earned Income) (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.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)
- STATE.MO.GAINS — Missouri exempts capital gains. From tax year 2025, 100% of federally reported capital gains are subtracted from Missouri income. Top rate 4.7%. (high, checked 2026-11-15 · Missouri DOR — capital gains subtraction (official))
- 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))
- US.NRA.SPOUSE — Non-U.S. spouse. Married to a non-U.S. person: file separately, or elect to treat the spouse as resident and bring their worldwide income in. (high, checked 2026-11-15 · 26 U.S.C. §6013 — joint returns, election for a nonresident spouse in (g) (official))
- US.TOTALIZATION — Social security totalization. The U.S. has agreements with France and the UK: you pay into one system only (usually where you work). (high, checked 2026-11-15 · SSA — International social security agreements (official))