September 16, 2026
A practical guide to holding both French and US citizenship: how the nationality side works, what changes once you’re a dual citizen, and the tax obligations that come with a US passport no matter where you live. Brought to you by the immigration team at LegalMova.
Both countries allow dual citizenship, and neither requires you to choose. France permits dual and even multiple nationality without any renunciation requirement, and current US law doesn’t force a citizen to give up another nationality either. Taking the French naturalization oath doesn’t put your US citizenship at risk, and becoming a US citizen through naturalization doesn’t require giving up French nationality.
That means the nationality side of this guide is short. The part that actually needs planning, and where most of the genuine complexity lives, is what happens once you’re holding both.
If you’re a US citizen looking to acquire French nationality, the routes are the same ones covered in our full guide to French naturalization: 5 years of continuous legal residence for the standard decree route (reduced to 2 years with a French Master’s-level diploma or above), or the marriage declaration route after 4 years of marriage to a French citizen (3 of them spent in France) or 5 years otherwise. Since January 1, 2026, the decree route requires B2 French and passing the new NAT civic exam, while the marriage route keeps the lighter B1 requirement and skips the exam entirely.
The reverse direction runs through standard US naturalization, generally requiring 5 years as a lawful permanent resident (a green card holder), or 3 years if married to and living with a US citizen throughout that period. Applicants file Form N-400, pass an English language test and a civics exam, and take the Oath of Allegiance. None of this requires giving up French nationality under current US law.
This is where the real planning happens, and it comes down to one fact that surprises a lot of new dual citizens: the United States taxes citizens on their worldwide income regardless of where they live. France, like most countries, taxes based on residence. The US is one of the only countries in the world that ties tax obligations to citizenship itself rather than where you actually reside, which means an American who has lived in France for 20 years and paid French tax on every euro earned still owes the IRS an annual filing.
Form 1040, the standard US income tax return, is due every year regardless of where you live or whether you owe anything. Most dual filers end up owing $0 to the IRS once relief provisions are applied, but the filing requirement itself never goes away simply because you live abroad.
The Foreign Earned Income Exclusion (FEIE), claimed on Form 2555, lets you exclude a set amount of foreign earned income (wages or self-employment income) from US tax. For 2025 the exclusion is $130,000, rising to $132,900 for 2026. It’s worth being precise about what this doesn’t cover: pensions, dividends, interest, capital gains, and most rental income aren’t eligible, so a dual citizen living mostly on investment income won’t get much shelter from FEIE alone.
The Foreign Tax Credit (FTC), claimed on Form 1116, is the other main tool, letting you credit French income tax already paid against US tax owed on the same income. Combined with the France-US income tax treaty, which allocates taxing rights between the two countries by income type, most dual citizens avoid genuine double taxation in practice, even though they still have to file in both places every year.
These catch people off guard because they’re easy to confuse with each other, and missing either one carries real penalties:
FATCA also creates a well-documented practical friction that’s worth knowing about before it surprises you: because FATCA requires foreign financial institutions to report US-citizen accountholders to the IRS, some French banks restrict or decline accounts for US citizens specifically to avoid that compliance burden. It’s not universal, but it’s common enough that dual citizens sometimes need to shop around for a French bank willing to take them on.
Some dual citizens, tired of the annual filing burden, eventually consider renouncing US citizenship. Two things are worth knowing if that ever comes up.
First, the administrative fee dropped significantly: the State Department cut it from $2,350 to $450, effective April 13, 2026.
Second, the fee was never the real cost for anyone with meaningful assets. The exit tax applies if you’re classified as a “covered expatriate,” which happens if you meet any one of three tests: worldwide net worth of $2 million or more, average annual US tax liability above $211,000 (2026 figure) over the prior 5 years, or failing to certify 5 years of full US tax compliance on Form 8854. If you’re a covered expatriate, you’re treated as having sold your worldwide assets the day before expatriating, with gains above a $910,000 exclusion (2026 figure) subject to tax.
One exception genuinely worth knowing: dual citizens by birth, meaning people born with both nationalities rather than someone who later naturalized, can avoid the net worth and tax liability tests entirely, provided they’re fully tax-compliant for the prior 5 years and meet specific residency conditions. This matters directly for children born to one American and one French parent, who often qualify as dual citizens from birth without ever having “chosen” US citizenship in the first place.
Do I have to choose between French and US citizenship? No. Neither country requires you to give up the other nationality, and there’s no legal conflict in holding both.
Will I be taxed twice on the same income? In most cases, no, thanks to the Foreign Tax Credit and the France-US tax treaty, but you’ll still need to file a US return every year regardless of whether anything is actually owed.
What’s the difference between FBAR and FATCA? They’re separate reporting regimes with different thresholds and different filing destinations. FBAR is filed with FinCEN once aggregate foreign accounts exceed $10,000; FATCA’s Form 8938 is filed with your tax return once specified foreign assets exceed the applicable threshold, generally $200,000 or $400,000 for Americans living abroad.
Why do some French banks refuse US citizens as clients? Because FATCA requires foreign banks to report US-citizen accountholders to the IRS, and some institutions decide the compliance burden isn’t worth it, restricting or declining those accounts instead.
If I was born with both nationalities, does the exit tax apply the same way if I ever renounce? Not necessarily. Dual citizens by birth can avoid the net worth and tax liability tests for covered expatriate status, provided they’ve stayed fully tax-compliant and meet residency conditions, an exception that doesn’t apply to someone who later naturalized into a second citizenship.
Every dual citizen’s situation looks different depending on how the citizenship was acquired, where the income actually comes from, and how much cross-border planning has already been done. Our team at LegalMova can help you think through the nationality side clearly, and connect you with the right tax specialists for the parts that need one.
Book your free consultation with our team and let us assess your situation in full. No commitment, no jargon, just clear answers about your path as a French-American dual citizen.
