• English
  • Français
  • Deutsch
  • Español
  • Italiano
  • Русский
Start
Investment Account in the US with Tax Residence in Europe

Investment Account in the US with Tax Residence in Europe

This article explains general principles and is for information only. It does not constitute legal or tax advice. Personal outcomes depend on residence, income type, cross-border links, documents, and timing.

What to Do If You Have Investments in the US and Live in Europe

This situation is far more common than many people expect. Someone may work, for example, in France, be a tax resident there, and at the same time hold an investment portfolio in the United States that was opened years earlier, sometimes long before the move. For a while, these look like two separate realities that do not interfere with each other.

Problems usually start not when the portfolio grows, but when the money needs to be used. Buying property, making a large transfer, changing banks, a tax inquiry, or a compliance check — any of these moments makes the entire structure visible.

From that point on, the question is no longer “is there a risk” but “how to structure the situation so that the risk is manageable.”


What a Typical Case Looks Like

  • The investment account is in the United States.
  • The current tax residence is in France.
  • Income comes from dividends, interest, and capital gains.
  • The money has not been touched for a long time.
  • A goal appears to use this capital in Europe.

At this point, past investments and current tax residence stop being separate stories. From a tax perspective, they become one system.

Related analysis of a similar situation:
Case on dual tax residence in France and the United States


What You Need to Understand First

It matters not only where the money is held, but also when it was earned. It matters not only where a person lives now, but from what date they became a tax resident of that country. And finally, a transfer of funds does not create a tax by itself, but it makes the entire structure visible to banks and tax authorities.

That is why the situation should be approached not through isolated questions, but through a single overall model.


A Basic Action Plan

1. Fix the date of tax residence change

Clearly determine the date from which you are considered a tax resident of France. This does not always match the moving date. This point defines which income is treated as “before” and which as “after.”

2. Split the capital by periods

Record which part of the income was generated before French tax residence and which after. This is not a formality. It is the foundation of the tax logic.

3. Identify the nature of the income

Dividends, interest, and capital gains are different categories with different tax and reporting rules. Treating everything as one “investment pot” leads directly to mistakes.

4. Review the France–US tax treaty

The double tax treaty does not eliminate taxes, but it allocates taxing rights between countries. You need to know which country has priority for each income category.

5. Build a reporting model

  • Separate obligations for France.
  • Separate obligations for the United States.
  • Separate reporting for foreign financial assets.

Even if tax is effectively paid in one country, reporting obligations may exist in both.

6. Plan money movements only after that

Transfers, property purchases, and reinvestments should take place within a clear structure, not before it exists.


Common Mistakes

  • Assuming that money earned long ago is automatically “out of scope.”
  • Believing that if tax was withheld somewhere, reporting no longer matters.
  • Looking only at the country of the account and ignoring the country of residence.
  • Following scattered advice instead of building one coherent model.

None of these mistakes seem critical until a major transaction appears.


How to Read This Case Correctly

This is not a story about “exotic tax complexity.” It is a story about ordinary financial life that at some point becomes cross-border.

If you have investments in one country and tax residence in another, you are already in this zone. The only difference is whether you realize it now or face it later, at the moment of your first major transaction.


FAQ

Capital accumulated in the US does not become neutral after moving to France.
For tax purposes, the moment income is earned and the moment tax residence changes must be clearly separated and documented.

A money transfer does not create tax, but it creates visibility.
Tax is paid on income, not on transfers. But transfers trigger attention from banks and tax authorities.

Investment income from the US remains cross-border income.
After becoming a French tax resident, this income falls under international tax rules and the bilateral treaty.

Reporting is not a formality, it is your protection.
Properly reported income rarely becomes a problem. Missing forms almost always do.

Property purchases are moments of maximum transparency.
Banks, notaries, and sometimes tax authorities review not only the amount but also the source of funds.

Individual tips do not replace a system.
Only a coherent model that includes income, residence, treaties, and reporting really works.

Articles and calculators rely on general assumptions. Your outcome depends on your specific circumstances. Richys structures your situation to define a clear position. A verified EU expert can provide a written conclusion.

Start case analysis
Define your position before decisions
Mathieu Fiscalis
Mathieu Fiscalis

AI assistant – Taxes & Cross-Border Tax

Mathieu Fiscalis