1️⃣ Assurance Vie

Why It’s Popular in France

• Tax deferral

• Flexibility

• Favorable inheritance rules

• Flat tax (Prélèvement Forfaitaire Unique – 30%)

  
  

The Challenge for US Expats

• Underlying funds = often PFICs

• Many insurers refuse US persons (FATCA)

• Complex US reporting
  

When It Can Work

• If structured with US-compliant assets

• If wrapper is used for euro fund only (case-by-case)
  

Hexa Invest point of view: Attractive for French tax residents but risky for Americans without expert structuring. Do not hesitate to contact us if you want some guidance on Assurance Vie.

2️⃣ Compte-Titres Ordinaire (CTO)

CTO is a standard brokerage account in France.

Pros

• No investment cap

• Full flexibility

• Access to global markets
  

Major Risk

• Most European ETFs = PFICs

• Complex IRS reporting (Form 8621)
  

Taxation

• 30% flat tax in France

• US taxation on worldwide income
  

Hexa Invest point of view : Simple legally, but can be dangerous if you buy the wrong ETFs.

3️⃣ Plan d'Épargne Retraite (PER)

PER are attrative because of of tax deduction on contributions and because it is a retirement-focused vehicle.

US Tax Uncertainty

• Not automatically recognized as pension by IRS

• Likely PFIC exposure

• Complex cross-border reporting
  

Hexa Invest point of view: The US–France tax treaty does not clearly classify PER. It is potentially problematic unless carefully structured. Be sure you ask some guidance before opening one.

4️⃣ Keeping a US Brokerage Account

(e.g. Charles Schwab, Fidelity Investments, Vanguard)

Why It’s can be the Safest Option

• Access to US-domiciled ETFs (no PFIC)

• Simpler IRS reporting

• No PRIIPs exposure (if account already open)
  

Limitations

• Some brokers close accounts after relocation

• Must manage French tax reporting carefully

• Estate tax exposure (US situs assets)

French tax applies but without punitive IRS regime.

For most US expats in France, the question is not “Which account has the best tax benefits in France?”
The real question is: “Which structure avoids punitive US taxation?”

Schedule a quick conversation with one of the experts of the Hexa Invest network.