September 10, 2025
When Americans become French tax residents, one of the first financial planning questions to arise is: How do I keep investing in the U.S. market, cleanly and compliantly?
Two forces shape the answer. First, European investor-protection rules change what a retail investor in France may buy on European platforms. Second, U.S. tax rules can treat many European funds unfavorably. Put differently, your access to the U.S. market and your tax treatment can both change once you become a French resident.
Although this adds complexity, there’s good news: with the right structure, you can maintain a U.S.-first approach, keeping broad exposure to the S&P 500 and U.S. markets without creating avoidable headaches.
Our philosophy at Liberty Atlantic Advisors is anchored in simplicity and longevity: keep your plan aligned with your long-term financial goals, adjusted for your new cross-border context and in coordination with your U.S. CPA and your French tax advisor so filings remain straightforward on both sides of the Atlantic.
Related reading: Building Your Cross-Border Team
What Changes the Day You Become a French Tax Resident
Once you update your legal address to France, several U.S. firms restrict new purchases in taxable accounts. Fortunately, most Americans nowadays are researching well in advance of a permanent move to France and become aware of this potential change well in advance of moving. This leads to an increased understanding of the nuances around maintaining U.S. investments after you move to France, but it still raises important questions.
In many cases, you may continue to hold what you already own, and some firms will still allow dividend reinvestment or internal rebalancing; others will not. These are policy decisions that vary by firm, so the exact experience differs from one custodian to the next. There is a ton of hearsay, so we always recommend floating the idea of a potential move in the hypothetical by your current broker or custodian. Test the waters before diving in, so to speak.
One advantage of choosing to partner with a cross-border financial firm is that, rather than relying on custodian responses, Liberty Atlantic proactively coordinates with U.S. custodians and French tax advisors to ensure your investment structure is durable from the outset. This prevents unpleasant surprises once you are already abroad.
Once You’re in the EU
You’ll encounter rules that determine what an EU-resident retail investor can buy. Two acronyms come up often:
PRIIPs, which stands for Packaged Retail and Insurance-based Investment Products. In short, if a fund is offered to EU retail investors, it must provide a standardized, short disclosure called a KID (Key Information Document) so buyers can compare products easily.
MiFID II, which stands for the Markets in Financial Instruments Directive (the 2018 update). Among other things, it classifies investors (retail vs. professional) and sets protections for retail clients.
Most U.S.-domiciled ETFs and mutual funds do not produce a KID, so EU platforms typically block retail clients in France from purchasing them. This is why the classic advice to “just buy VOO” tends to stop working after you move, even though nothing about VOO itself has changed.
Next, there’s the U.S. tax lens. You’ll see "PFIC" referenced often; it stands for Passive Foreign Investment Company. In plain English, many non-U.S. funds, e.g., most UCITS ETFs, local mutual funds, and fund-based life-insurance wrappers fall into this category for U.S. taxpayers when held in taxable accounts.
PFICs bring two challenges: potentially punitive U.S. taxation and annual Form 8621 reporting for each PFIC you own. This is the core reason we prefer U.S. securities and PFIC-free construction in taxable accounts.
Read more: High-Net-Worth Tax Planning Strategies for Americans in Europe
Two Paths, Same Goal: A U.S.-First Plan That Works in France
A) Before You Leave the U.S.: The Above-Board Track
If you’re still stateside, choose your operating model first: can you implement this yourself, or is it wiser to engage a cross-border fiduciary? And, if you already work with an advisor, do they truly understand U.S.–France constraints? This decision drives everything that follows. From there, get organized. Confirm—in writing, if possible—how your U.S. custodian will treat your accounts once your legal address is in France:
Will new purchases in taxable accounts be blocked?
Will dividend reinvestment or internal rebalancing continue?
How are corporate actions handled for French residents?
Has this information been confirmed by leadership at the brokerage?
Knowing the rules upfront prevents unpleasant surprises.
If you’re a retail investor moving abroad with a DIY mindset
You’ll want to simplify your holdings in anticipation of the move.
In taxable accounts, favor individual U.S. securities so you avoid PFIC issues later; where appropriate, place broad-market ETF exposure inside U.S. retirement accounts that often continue to permit fund trading post-move (even on this point, though, custodian policies vary).
This is also the right moment to clean up old accounts, confirm beneficiaries (mind that you evaluate your estate plan with a French tax lawyer before you go, though!), and set a cadence for rebalancing that won’t be derailed by residency changes.
Consider working with a cross-border firm
In some cases, the restrictions that accompany investing in the U.S. from France may lead you to consider partnering with a cross-border financial planning firm. Ongoing access to ETFs and adapting a U.S. plan for a U.S.-France context is well within the purview of qualified firms.
As an example, Liberty Atlantic Advisors is a cross-border, SEC-registered, fee-only fiduciary serving Americans in select countries in Europe, including France. We also have strong partnerships with a dedicated U.S. expat CPA and French tax advisor, so the mechanics—treaty application, reporting, and paperwork—match the portfolio you actually hold.
If you currently have a U.S.-based financial planner
You will want to confirm their capacity to continue to support your portfolio transition to a U.S.-first, PFIC-aware construction and ideally provide two-country filing support.
Related reading: Retiring in France as an American (Financial Considerations)
B) Already in France and Considering the “Gray-Area” Track
Some Americans maintain a U.S. mailing address to keep their brokerage experience unchanged. It’s common—but it poses long-term risks to your finances.
If your custodian later identifies your foreign residency, you could face trading freezes, forced changes of custodian, or even short-notice liquidations. You may also find that, even if an institution will keep you, you’re restricted in what you can buy and how you operate.
If you decide to operate in this gray area, calculate the risk carefully and with an exit ramp in mind. If you receive word that your U.S.-based brokerage will no longer be able to support you, consider the following:
Immediate triage with a cross-border planner working with Americans in France. Establish priorities based on your positions, taxes, and timeframes.
Export everything. Secure statements, cost basis, lot history, and transaction reports from every account.
Choose the landing zone. Realistically assess where your assets can live next: options for retail investors are limited, and onboarding can be slow, particularly if you opt for an EU-registered brokerage. The adage, “time moves more slowly in Europe,” very much applies to financial institutions, too. Additionally, financial services in Europe tend to be much more expensive, which can take folks accustomed to U.S. fees by surprise.
Transfer, don’t thrash. Where possible, arrange in-kind transfers (ACATS or equivalent) to avoid unnecessary sales. If liquidation is forced, sequence sales to manage taxes thoughtfully.
Set decision triggers. Agree in advance which custodian messages (address certification requests, trading blocks, KYC refreshes) flip you from “monitor” to “move.”
While the aim here isn’t to normalize (and definitely not to encourage) operating in the gray area, we would be remiss not to address it.
That said, we highly encourage you to get organized and compliant ahead of a move, whether that looks like you reorganizing your portfolio yourself or starting a relationship with a cross-border firm specialized in maintaining U.S. investments and planning for your ongoing financial wellness in the context of a long-term or permanent move to France.
Account Types: What You Can (and Can’t) Do
It helps to separate taxable accounts from retirement accounts.
In a U.S. taxable brokerage after your move, you can usually continue to hold what you already own, and most custodians will let you buy and sell individual U.S. securities such as stocks (and sometimes individual bonds or CDs).
Where you’ll feel the constraint is in new purchases of U.S.-domiciled ETFs or mutual funds: many firms disable those orders for French residents. Some will still allow dividend reinvestment or internal rebalancing within existing fund positions; others won’t. Knowing your firm’s policy is essential so you can design around it.
By contrast, U.S. retirement accounts (IRAs, Roth IRAs, and 401(k)s) often remain the easiest home for broad-market exposure inside the wrapper after you relocate. Whether you can contribute new money is a separate, rules-based question: contributions typically require U.S.-source earned income. (Note that income excluded under the Foreign Earned Income Exclusion generally does not qualify.)
From a planning perspective, it may be efficient to place assets in retirement accounts that would be more heavily taxed in France if held in taxable form. But best practice here would involve close analysis of the U.S.-France tax treaty and, ideally, input from a French tax lawyer.
A note on French products from a U.S. perspective
A basic savings account like Livret A is simple and low-yield – not complicated from a U.S. tax reporting perspective.
Vehicles such as the PEA (Plan d’Épargne en Actions) or assurance vie often hold fund structures that look efficient locally but are treated as PFICs for U.S. tax purposes when owned in taxable accounts. They can be appropriate in specific circumstances, but only with bespoke cross-border tax guidance and a clear understanding of the U.S. reporting that comes with them.
Before we choose building blocks, it helps to understand how the U.S.–France tax treaty treats U.S.-source dividends, interest, and certain gains.
How the U.S.–France Tax Treaty Fits into a U.S.-First Plan (Overview)
Two treaty provisions are especially relevant once you’re a French tax resident with U.S. investments.
Article 18 (Pensions) distinguishes between U.S. Social Security and other private retirement income: Social Security remains taxed by the United States, while private pensions (like 401(k)/IRA distributions) are coordinated under the treaty so the two countries don’t tax the same dollars twice.
Article 24 (Relief from Double Taxation) is the mechanism France uses to remove double tax on certain U.S.-source portfolio income—such as dividends and interest paid by U.S. issuers—by granting a credit on the French return. In practice, you still report the income in France, but the credit neutralizes the French income-tax layer where the treaty applies.
A few caveats keep this grounded:
“U.S.-source” refers to income from U.S. issuers; a fund full of non-U.S. stocks doesn’t become U.S.-source just because it sits in a U.S. account.
The treaty also doesn’t override PFIC rules; non-U.S. funds held in a taxable account can still trigger Form 8621 and unfavorable U.S. tax.
And separate from income tax, France may apply healthcare-related contributions to investment income (part of PUMa/CSM).
Our approach is to build taxable portfolios from U.S. securities so you can rely on the treaty credit method cleanly, keep broad-market ETFs inside U.S. retirement accounts when your custodian permits it, and coordinate filings on both sides so the paperwork supports the outcome.
With that framework in place, here’s how we maintain broad U.S. market exposure in practice.
Maintaining S&P 500 Exposure – Planning in France
1) Retirement accounts first
If your IRA/401(k) allows it post-move, keep broad-market or S&P 500 ETF exposure inside the retirement wrapper. It’s clean, diversified, and usually the easiest place to maintain your core allocation.
2) Individual stock sleeve in taxable.
In your taxable account, you can approximate an index by holding a rules-based list of individual U.S. stocks. Trade-offs: small tracking error vs. the benchmark, plus modest ongoing maintenance for rebalancing and changes. The benefit: no PFICs and cleaner documentation for both tax systems.
3) Professional-client route (optional)
If your profile meets a broker’s criteria (asset levels and/or trading experience), EU platforms may permit you to buy U.S.-domiciled ETFs as a “professional client.” This isn’t necessary for everyone, but it’s a legitimate path for some.
Cross-Border Compliance Overview for U.S. and France
Below are a few of the standard compliance criteria required when you move to France as a U.S. taxpayer. Note that these lists are not exhaustive, and you should confirm your compliance checklist with your cross-border tax professionals.
U.S. filings:
Form 1040 annually, even while abroad
FBAR (FinCEN 114) for foreign accounts when the aggregate exceeds $10,000
FATCA (Form 8938) for specified foreign financial assets above thresholds
Form 8621 for every PFIC each year (if any)
France filings:
Report dividends, interest, and capital gains; keep clean U.S. statements your French accountant can interpret.
Documentation hygiene: Save annual statements in USD (and EUR where relevant), dividend/withholding detail, and lot-level transaction reports. Your future self—and your accountants—will thank you.
Concluding with a Few Mythbusters
Myth: “I can’t own U.S. ETFs at all once I’m in France.”
Reality: You often can keep existing holdings; the common restriction is new purchases in taxable accounts if you are a retail investor. This limitation does not apply when you work with an advisor. Myth: “A European S&P 500 ETF is a clean substitute.” Reality: In a U.S. taxable account, most are PFICs with heavy reporting and potentially punitive taxation.
Myth: “Any advisor helping Americans is fine.”
Reality: Confirm fiduciary, fee-only status, and where the firm is regulated. For Americans in France, a U.S.-registered advisor with cross-border expertise helps you stay U.S.-centric and compliant without risking detours into PFIC-heavy products.
Takeaway Checklists Any American Moving to France Can Act On Pre-Move
(6–12 months out)
Reorganize your portfolio to be cross-border compliant and optimized (e.g., S&P 500/broad-market ETFs) before the move.
Ask your current broker what changes after you update residency (dividend reinvesting plan (DRIP), rebalancing, corporate actions).
Review state tax residency rules to cleanly exit your former state.
Already in France
Inventory your accounts; identify any PFIC exposure.
Decide your S&P 500 route: retirement accounts, individual stocks in taxable, or professional-client access.
Confirm U.S. filings (FBAR/FATCA/8621) and French reporting.
Set a rebalancing cadence and documentation routine so tax time isn’t a scramble.
How Liberty Atlantic Implements a U.S.-First Plan
SEC-registered, fiduciary, U.S.-first. We manage U.S. investments for Americans living in France. We do not manage European investments—our mandate is to keep your plan simple and strategically aligned with your long-term financial goals.
Clean portfolio construction. We prioritize low-risk investment strategies and a diversified asset portfolio designed to weather global volatility and in anticipation of any headwinds.
Two-country coordination. We collaborate with your U.S. expat CPA and French tax advisor to help streamline your tax and financial management.
Process you can live with. Transparent fees and regularly scheduled meetings. Open lines of communication and timely responses to email and questions.
Ready to Explore Working Together?
When Americans transition to French tax residency, one of the most important financial questions arises: how does one maintain and grow U.S. investments in a compliant, tax-efficient, and long-term strategic way?
At Liberty Atlantic Advisors, we help clients structure their portfolios so they remain firmly anchored in the U.S. market while taking into account their new cross-border context.
If you’d like support creating or adapting a current U.S. financial plan for a long-term move to France, please reach out to Liberty Atlantic Advisors.
References
Disclaimer
This material is purely intended to be general and educational in nature, and should not be construed as specifically-tailored investment, financial planning, tax, legal, or other professional advice. Information and data contained herein is as-of the date of publication, and may be subject to change in the future without notice. Any investment performance referenced is purely past performance, which is no guarantee of any future performance. Nothing contained herein should be construed as an offer to sell, a solicitation of an offer to buy, or a recommendation of any security or other financial product or investment strategy. All investment, tax, and financial planning strategies involve risk that you should be prepared to bear. You are highly encouraged to consult with professionals of your choosing before taking any action based on this material.
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