Should you file your French tax return before your US one?

Unlike other nationalities, Americans abroad are still required to file a US tax return regardless of where they live, thanks to citizenship-based taxation.

As such, springtime means preparing both a US and French tax return for Americans in France.

Americans abroad are given an automatic two month extension on their US tax return, meaning it is due by June 15th (instead of April 15th), assuming you have not requested another extension on top of that.

As for the French tax declaration, this year the online form opens on April 10th. The due date has not yet been announced, but typically, it is due by late May or early June (depending on where in France you live).

READ MORE: The bumper French tax guide for 2025

To help you determine which tax return to submit first, The Local spoke with tax adviser and expert Jonathan Hadida, from HadTax, who explained that the filing order is about "avoiding double taxation". 

He said: "The main question to ask yourself is: do I have French income? If this is the case, then usually it is best to file your French tax return before your American one.

"This might be a French salary, rental income, or French investment income, like capital gains.

"As with everything related to taxes - it depends on your individual facts and circumstances. Everybody is different, but there are some guide lines," Hadida said.

He went on to give a few examples to highlight common scenarios. 

American working in France

"If this person - who earns a French salary and pays French taxes - wants to use the 'foreign tax credit', then they may want to file the French return first in order to get at least an estimate of their French taxes.

"They could also wait to have the French avis (final assessment) before filing the American return. To do this, you could request an extension in the US until October or even December.

"Asking for an extension would help ensure you enough time to get all the information needed for the tax credit when filing your US tax return," Hadida said.

That said, the foreign tax credit is one of the two ways Americans can avoid double taxation, the other is the foreign earned income exclusion (FEIE). 

When choosing between the two, there are several variables to consider, including whether or not you are contributing to a US IRA or if you want to benefit from the US child tax credit.

Hadida explained: "If you take the foreign earned income exclusion, then you could file the US return first. This is a simple and quick option.

"But it is possible you'd be better off doing the foreign tax credit. If you take the foreign earned income exclusion, you cannot benefit from the child tax credit. This means that if you have kids in France, and you opt for foreign earned income exclusion - you might be giving up a significant refund from the US," he said.

American retiree in France

"Let's look at the example of someone who only earns US sourced pension or investment income. This person does not have any French income.

"They could file the American return first, there's nothing stopping them. As long as they don't need any foreign tax credit information, there's no downside to filing the US return first and then doing the French one after.

"The general rule of thumb is that for a retiree without French income, the order doesn't really matter. It's up to you and your preferences," Hadida said.

However, if this American retiree has some income in France, the picture changes somewhat.

"If you have rental income, or investment income (including capital gains) in France, you're going to owe French taxes on it. There may not be US taxable income, but if there is, then you would need the French tax credit to offset US taxes in order to avoid double taxation.

As for pension income, the US-France tax treaty is very clear "It is only taxable in the state you received it," Hadida said. This means a US-sourced pension is only taxable in the US, and a French pension is only taxable in France.

While you need to declare your US pension on your French tax declaration, you will not owe any French taxes on it.

READ MORE: Ask the expert: What Americans in France need to know about 401(k) and other pensions

American who expects to owe US taxes

If you have French income, you may have decided it is best to file your French return first. However, if you think you will also owe US taxes, then you have some other factors to consider.

"In this case, you might be better off paying something to the IRS by April 15th to mitigate any interest or penalties from accruing. 

"For example, if someone has significant investment income in the US - that income is only taxable in the US. We would want to calculate how much this person would likely owe in US taxes, so basically we would prepare the US tax return as if we are going to finish it.

"Then you would make a payment to the IRS based on what you expect to pay, and we will file the return later. 

"Your balance will be zero, so you won't have any interest or late-payment penalties accruing. 

"Ultimately, this decision should be made on a case by case basis, and it will depend on how much you expect to in US taxes, as well as your personal preferences," Jonathan said.

What happens if you accidentally file in the wrong order?

Jonathan explained that in this case, you could amend the return.

"However, amending the return will make it take much longer (as in several months) to get your refund. This is why you're probably better off requesting an extension for the American return," Hadida said.

You can learn about how to amend a return or request an extension on the IRS website.