Educational and informational only. This guide reflects rules checked in October 2026 and is not credit, tax or legal advice. Amberlake Partners is not a mortgage broker or credit intermediary and does not arrange or offer loans; any financing is provided and decided solely by the lending bank. Tax rules, lending criteria and bank policies change, and each situation requires review by qualified professionals in the US and in the country concerned.
Who this guide is for
This page is for US citizens and green card holders who live in France, are moving there, or are buying a home there while living elsewhere. It brings the main questions together in one place: where to bank, how to invest without creating US tax problems, and how property financing from banks generally works.
If you are still planning the move itself, start with our guide for Americans moving to France. If financing is your main question, our detailed comparison of French property financing for US citizens goes further on each route.
Why French banks hesitate with US persons
France signed a Model 1 FATCA intergovernmental agreement with the United States, in force since 2014. French banks identify US persons and report their accounts to the French tax authority, which passes the information to the IRS.
The reporting is routine, but it carries a cost. Some banks limit what a US person can hold, for example by declining investment advice or restricting funds, and some branches prefer not to open the relationship at all. The answer you receive often depends on the bank, the desk and the size of the relationship rather than on a published rule.
Two practical points follow. First, keep a working US account while you organize the French side, because some US brokers restrict accounts once you report a foreign address; see what happens to your US brokerage account. Second, approach banks with a complete file, including your US tax status documents, rather than discovering the requirements one appointment at a time. Our overview of European banking and FATCA for US expats covers the options.
US reporting does not stop when you move
The United States taxes its citizens and green card holders on their worldwide income, wherever they live. Moving to France does not end US filing. It adds a second set of rules on top.
In practice, the US layer usually includes the annual federal return, the FBAR (FinCEN Form 114) when the combined balance of foreign financial accounts exceeds $10,000 at any time in the year, and Form 8938 (FATCA) when foreign financial assets pass the IRS thresholds. For a single filer living abroad, those thresholds are $200,000 on the last day of the year or $300,000 at any time; they are higher for joint filers.
On the French side, a tax resident must declare foreign accounts and certain foreign life insurance contracts with the annual return (form 3916), and French real estate held above €1.3 million net is subject to the real-estate wealth tax (IFI), including for non-residents on their French property. The US–France income tax treaty helps prevent double taxation on many types of income, but it does not remove the filing work in either country.
The practical consequence is that every account, policy and fund you open locally has a US reporting cost as well as a local one. Planning the structure before you move is usually cheaper than unwinding it afterwards.
The PFIC problem with local investment products
Many products sold to residents, such as French and Luxembourg funds held inside an assurance-vie contract or a PEA, invest through non-US pooled funds. For US tax purposes, most non-US mutual funds and ETFs are treated as Passive Foreign Investment Companies (PFICs).
PFIC treatment can mean punitive tax calculations on gains and certain distributions, interest charges and an annual Form 8621 for each fund. A portfolio that is efficient for a local resident can therefore be inefficient for a US person living in the same building.
The usual approach is to build the portfolio from instruments that work on both sides: individual securities, US-domiciled funds where the custodian and local rules allow them, and bonds held directly. Whether a given product is a PFIC depends on its structure, so it should be checked with a US tax adviser before you buy it. Our guide to PFIC rules for Americans living in Europe explains the mechanics.
How bank financing generally works for US persons in France
French mortgages follow binding rules set by the High Council for Financial Stability (HCSF), in force since 1 January 2022: total debt service, including borrower insurance and existing loans, should not exceed 35% of net income, and the term is generally capped at 25 years. Banks may depart from these limits for a small share of their lending, mostly reserved for primary residences, so non-resident and second-home files rarely benefit.
Within those limits, each bank sets its own policy on deposits, income in foreign currency and US persons. Dollar income is commonly accepted but may be discounted for currency risk. The deposit you will be asked for depends on residency, income, the property and the lender, so treat any general percentage you read online as indicative only.
Wealthier buyers often compare a French mortgage with portfolio-backed financing, where a private bank lends against a diversified securities portfolio. This can avoid selling investments and may move faster than a property mortgage, but it adds margin-call, interest-rate and currency risks that need to be understood before signing.
Process: from first call to signing at the notaire
1. Map your position. List assets, custodians, income sources, existing debt and the US tax status of each account. Decide whether you will be a French tax resident.
2. Choose the financing route. Compare a French mortgage, portfolio-backed credit and cash, or a combination, before making an offer.
3. Prepare the file. Passport, proof of address, two or three years of US returns, income evidence, bank and custody statements, a schedule of liabilities and evidence of the origin of funds.
4. Approach suitable lenders. Present the file to banks that work with US persons and obtain an indication of terms in writing.
5. Sign the preliminary contract. Have the compromis or promesse de vente reviewed so that any financing condition reflects the route you are actually pursuing.
6. Complete and organize the portfolio. After signing the deed at the notaire, set up the investment structure so that it works for both US and French reporting.
How Amberlake Partners works with US persons
Amberlake Partners SAM is a wealth management firm in Monaco, licensed (agréée) and regulated by the Commission de Contrôle des Activités Financières (CCAF) and registered with the US Securities and Exchange Commission (CRD 322274). You can verify the registration on the SEC's Investment Adviser Public Disclosure website and read our Form ADV brochures, linked at the foot of this page.
We work on an external asset manager model: your assets stay in your name at a custodian bank, and we advise on and coordinate the portfolio across the institutions you hold. Booking centres available through our partner banks include Monaco, Geneva, Luxembourg, Madrid, New York, Miami, Dubai and Singapore. There are no in-house products to place.
Amberlake Partners is not a mortgage broker or credit intermediary and does not arrange, negotiate or offer mortgages or loans. Around a property purchase, our role is limited to advising on the wealth and portfolio side, for example the liquidity, currency and portfolio consequences of paying cash or borrowing, and assisting with banking relationships, as described in our Form ADV. If a client asks a partner bank about financing, any loan is offered and decided solely by that bank, at its sole discretion and under its own onboarding, compliance and credit criteria. We cannot promise that a bank will open an account or extend credit.
Common questions
Can a US citizen get a mortgage in France?
Yes. Some French lenders finance US citizens, both residents and non-residents, within the HCSF limits of 35% debt service and a 25-year term. FATCA compliance narrows the number of banks willing to take the file, so lender selection and a complete file matter.
Will a French bank open an account for an American?
Many will, but policies vary by bank and by branch. Some accept US persons only for everyday banking, others for investment services as well. A complete file with your US tax documents shortens the process.
Is an assurance-vie a good idea for a US citizen?
It depends on the contract. Funds held inside many French and Luxembourg contracts can be PFICs for US purposes, and the contract itself has US reporting consequences. Review it with a US tax adviser before subscribing.
Do I still file US taxes if I live in France?
Yes. US citizens and green card holders file a US return on worldwide income wherever they live, plus FBAR and Form 8938 when thresholds are met. The US–France treaty helps avoid double taxation but does not remove the filings.
Can I borrow against my portfolio instead of taking a mortgage?
Potentially. A private bank may lend against a diversified portfolio held in custody. It can avoid selling investments, but the loan can be called if the portfolio falls, and rates are often variable.
Does Amberlake Partners arrange mortgages?
No. Amberlake Partners is a wealth manager, registered with the SEC and licensed by the CCAF. It is not a mortgage broker or credit intermediary and does not arrange, negotiate or offer loans. Any financing is provided and decided solely by the lending bank, at its sole discretion.
Sources checked for this guide
Rules and figures quoted on this page were checked on 25 October 2026:
FinCEN: Report of Foreign Bank and Financial Accounts (FBAR)
IRS: Do I need to file Form 8938?
HCSF decision D-HCSF-2021-7 (35% debt-service and 25-year limits), via economie.gouv.fr
US Treasury: FATCA intergovernmental agreements by jurisdiction
Important information. This page is educational and informational only. It is not credit, tax or legal advice, and it is not an offer or solicitation for any loan or financial product. Amberlake Partners SAM is a wealth manager registered with the US Securities and Exchange Commission and licensed by the CCAF in Monaco. It is not a mortgage broker or credit intermediary and does not arrange, negotiate or offer mortgages or loans. Any financing is provided and decided solely by the lending bank, at its sole discretion.