French trust: taxation, reporting requirements, and US expat obligations in 2026

If you are an American living in France with a trust – as settlor, beneficiary, or named trustee – you sit at the intersection of two legal systems that disagree on what a trust is.

Any American living in France with trust connections faces the same setup: France does not recognize the common-law trust, but France's trust tax rules still reach the settlor and the beneficiary and require annual declarations.

The US requires its own information returns on the same structure regardless of what France does. This guide covers both sides for tax year 2025 (filed in the 2026 filing season), with forward figures for tax year 2026 [filed in 2027] noted where the rules are already set.

We walk through the regime under Article 792-0 bis CGI, annual and event-based declarations, IFI and DMTG exposure, and every US filing your involvement can trigger – Forms 3520, 3520-A, FBAR, and 8938. Cross-border trust France-US exposure is one of the most under-planned areas of expat trust planning in France, which is why we treat both sides in the same guide.

What is a French trust? Key concepts for US expats in France

Three core facts to know:

1. France does not recognize trusts under civil law, so a foreign trust has no independent French legal personality.
2. Foreign trusts connected to a French tax resident (settlor, beneficiary, or trustee) or holding French-situs assets trigger mandatory French reporting under Article 1649 AB CGI.
3. Failure to declare currently carries a flat €20,000 penalty per missing filing (tax year 2025). The 12.5% asset-based penalty in older guidance was struck down by the Conseil constitutionnel in decision 2016-618 QPC of 16 March 2017.

France treats foreign trusts as fiscally transparent, meaning the settlor or beneficiary – not the trust itself – owes French tax. The framework was introduced by the Loi de finances rectificative of 29 July 2011 and codified in Article 792-0 bis CGI.

For a US expat, this creates a two-tier obligation: French declarations for the trust structure, plus US information returns for the same trust.

There is no living trust in French domestic law that mirrors the Anglo-American concept. The closest civil-law equivalent is the fiducie, which is narrower in scope and rarely used for private estate planning.

Trustees in French tax terminology are simply the persons administering the trust; the term is imported wholesale from the trust's home law, since French civil law has no equivalent role.

You can review our foreign trust primer for the full US definition of what counts as a foreign trust.

French trust law: why France does not recognize common-law trusts

France has no common-law trust tradition, and French trust law does not exist as a codified body. The nearest domestic instrument is the fiducie, introduced by Law 2007-211 of 19 February 2007 and defined in Article 2011 of the French Civil Code.

The fiducie is a fiduciary transfer for a specified purpose – it is not a trust.

The fiducie cannot be used for private wealth transfer or estate planning, which places it far outside the functional space that Anglo-American trusts occupy. Only credit institutions, insurers, investment firms, and lawyers can act as fiduciaires, and the arrangement must serve a management or security purpose.

This is one reason a French fiducie vs trust comparison rarely helps a US expat: the tools do not overlap.

For foreign trusts, French courts have addressed cross-border trust questions narrowly, through case law rather than a general statute. In Cass. com., 13 September 2011 (Société Belvédère), the Cour de cassation recognized that a trustee or security agent governed by foreign law can have standing to file a proof of debt in French insolvency proceedings – a specific ruling on creditor standing, not a general rule that French courts always look through a trust's form.

Later inheritance-tax cases have applied the same look-through analysis to determine which party bears the French tax.

The trust civil effects France recognizes are limited, but not absolute: French courts do not automatically override a foreign trust or will that departs from the réserve héréditaire for French-situs assets, unless the deceased or a child is an EU national or resident and the foreign law leaves that child with no equivalent protection at all – in which case French-situs assets can be clawed back under Civil Code Article 913, paragraph 3.

Read our full explainer on offshore corporation structuring benefits and drawbacks for how these boundaries interact with US planning.

How France taxes foreign trusts: the CGI framework

France trust tax works through a look-through model under Articles 792-0 bis and 123 bis CGI. The framework attaches French tax to the settlor, the "deemed constituent" (bénéficiaire réputé constituant), or the beneficiary depending on the transaction.

The trust itself is disregarded as a separate taxpayer. Rates run from ordinary income tax up to 60% DMTG on French inheritance tax trust transfers.

Under Article 792-0 bis CGI, France taxes trust assets as if the trust did not exist. The four rules that flow from this framework:

1. Trust assets are included in the settlor's taxable estate. For inheritance and IFI purposes, France treats the settlor (or the trust deemed constituent after the settlor's death) as if they owned the trust property directly.
2. Distributions to French-resident beneficiaries are taxed as income or gifts. Depending on whether the distribution is of trust income, capital, or a share of the corpus at extinction, the amount is subject to French income tax or to DMTG (droits de mutation à titre gratuit).
3. Undistributed income of a foreign trust may be attributed to the French-resident settlor under Article 123 bis CGI, particularly where the trust sits in a low-tax jurisdiction. This is the French anti-deferral rule applied to trust structures.
4. The Loi de finances rectificative of 29 July 2011 created a specific anti-avoidance regime for trusts. It introduced Article 792-0 bis CGI and Article 1649 AB CGI, and set the current French trust taxation architecture.

For US expats, the crucial point is that France does not respect the US grantor/non-grantor distinction for its own tax purposes: both types are looked through.

See our guide on when foreign tax paid in France counts toward US relief for how the two systems interact on the income side.

French trust reporting requirements: forms, deadlines, and who must file

Any trustee administering a trust with at least one French-resident party – or a trust holding French-situs assets – must file Imprimé 2181-TRUST2 annually by 15 June, and Imprimé 2181-TRUST1 within one month of any qualifying event. The obligation sits on the trustee under Article 1649 AB CGI, not on the settlor or beneficiary.

French-resident parties can be held jointly liable for penalties. A French tax resident trustee has the same annual filing burden as a non-resident trustee, plus personal French income tax exposure on any trust income treated as their own.

The trust reporting obligations France imposes are broader than most US expats expect: three separate French trust reporting requirements apply in parallel, and each carries its own deadline and its own penalty exposure.

The following table summarizes the three French trust declaration obligations for tax year 2025.

 

Filings go to the Service des impôts des non-résidents (SIP des non-résidents) in Noisy-le-Grand. Paper filing only – the 2181-TRUST forms cannot currently be submitted electronically.

The scope covers every trust account in French records where a French tax resident is a party. Anti-avoidance rules under Article 123 bis CGI mean even a purely foreign trust with a French-resident settlor is caught.

Where trust-held French real estate is involved, a parallel French IFI trust reporting layer applies on Form 2042-IFI (covered in the IFI section below).

Read our full guide to FATCA and CRS reporting requirements for how automatic information exchange feeds the French tax office data on the same trusts.

Automatic exchange is why France trust disclosure gaps rarely stay hidden, and why French trust reporting requirements and France expatriate trust reporting compliance have tightened materially since 2018.

 

Talk to a US expat tax specialist about your France return

We prepare US expat tax returns for hundreds of Americans in France every year, including cases involving foreign trust reporting.

We handle the US side – Forms 3520, 3520-A, FBAR, 8938, Schedule B – and flag your French filing obligations so you can coordinate with a French avocat fiscaliste on the 2181-TRUST forms.

Talk to us today about your foreign trust reporting

Learn more

French trust taxation: IFI (wealth tax) and trust assets

France's Impôt sur la Fortune Immobilière (IFI) replaced the older ISF in 2018 and applies to net taxable real estate wealth above €1.3 million (tax year 2025 and tax year 2026).

Trust-held French real estate falls within the IFI base of the person deemed to own it – almost always the settlor or the bénéficiaire réputé constituant.

Trust-held French real estate is fully includable in the IFI base at its market value as of 1 January each year. The four IFI rules that apply to trusts:

• French-resident settlors must include trust-held French and foreign real property in their IFI base.
• The IFI threshold is €1.3 million net; the progressive rate scale runs from 0.5% to 1.5%.
• Non-resident settlors are also caught if the trust holds French-situs real estate, but only on the French portion.
• The trustee must report IFI-liable assets on the annual trust declaration (2181-TRUST2), and the taxpayer must include them on Form 2042-IFI.

Where the IFI-liable person fails to file, Article 990 J CGI imposes a sui generis levy at 1.5% of the trust's asset value – the highest IFI rate applied as a stand-in charge.

This is the actual asset-based exposure that remains in force after the 2017 constitutional ruling struck down the 12.5% penalty.

For US expats, IFI is not creditable against US tax because it is a wealth tax on assets, not income – French wealth tax trust assets sit outside the foreign tax credit regime entirely.

Understand how French inheritance and estate taxes reach expatriate estates for the broader interaction with US estate planning tools.

DMTG and French inheritance tax on trust distributions

Droits de Mutation à Titre Gratuit (DMTG) is France's gift and inheritance tax.

Under Article 792-0 bis CGI, DMTG applies to trust distributions treated as gifts or inheritances, at rates from 5% to 45% for direct-line transfers (parent-child) and up to 60% for unrelated beneficiaries (tax year 2025).

A trust distribution to a French-resident beneficiary is characterized under French rules, not the trust's governing law, and the characterization drives the trust distribution France tax rate.

Direct-line rates apply progressively across bracket amounts up to €1.805 million; the top 45% rate applies above that.

The 60% flat rate under Article 792-0 bis CGI applies where the settlor-beneficiary relationship cannot be established, where the trustee is subject to a non-cooperative jurisdiction, or where the trust was created after 11 May 2011 with a French-domiciled settlor.

For US expats, this changes the estate-planning arithmetic sharply. A US grantor trust distribution to a French-resident child of the grantor is characterized as a parent-child transfer and taxed on the DMTG parent-child scale – not as ordinary income.

The DMTG France trust interface is one of the tax puzzles most likely to catch US expats who assumed the US grantor-trust classification would apply on both sides.

 

 

Our foreign grantor trust guide explains the US mechanics; the French treatment sits on top.

US trust reporting obligations for Americans living in France

A US person with any interest in a foreign trust owes the same US filings whether they live in Manhattan or Marseille.

US expat trust reporting France exposure is a US federal duty, not a French one – the US filings track the settlor and the beneficiary regardless of where they live. The following five US filing obligations apply to trust-connected US expats in France:

1. Form 3520 – annual return for US persons with reportable foreign trust transactions, ownership, or distributions. Due 15 April (extended to 15 October); filed separately from Form 1040.
2. Form 3520-A – annual information return of the foreign trust itself. Due the 15th day of the third month after the trust's year-end (15 March for calendar-year trusts). If the trust does not file, the US owner must file a substitute Form 3520-A.
3. FBAR (FinCEN 114) – required if the aggregate value of foreign financial accounts (including trust accounts) exceeds USD 10,000 at any point during the year. Due 15 April, with automatic extension to 15 October.
4. Form 8938 (FATCA) – required if specified foreign assets exceed USD 200,000 at year-end / USD 300,000 at any time for single filers abroad (higher for MFJ). Filed with Form 1040.
5. Form 1040 Schedule B – requires disclosure of any interest in a foreign trust in Part III, regardless of dollar thresholds.

A US person who fails to file Form 3520 on time faces an initial penalty equal to the greater of USD 10,000 or 35% of the gross value of trust property transferred or distributed (Internal Revenue Code §6677). Additional penalties accrue if the failure continues after IRS notice.

The US-France tax treaty does not remove any of these US information-reporting obligations; treaty relief operates on the substantive tax, not on filing duties.

For the full framework on Form 3520 as it applies to US persons abroad, our dedicated Form 3520 walkthrough covers every part of the form.

Form 3520 and Form 3520-A: what US expats in France must know

Form 3520 is filed by the US person (settlor, transferor, or beneficiary); Form 3520-A is filed by the foreign trust.

Where the trust does not file Form 3520-A – common for foreign trusts with no US administrative connection – the US owner must attach a substitute Form 3520-A to their own Form 3520.

The Form 3520-A penalty is the greater of USD 10,000 or 5% of the gross value of the US-owned portion of trust assets (tax year 2025). Relief may be available for narrowly defined tax-favored foreign retirement and savings trusts under Rev. Proc. 2020-17.

Most France-related trust situations – US revocable living trusts holding French property, family estate-planning trusts – do not qualify.

Based on our client scenario at TFX: a US citizen living in Lyon is the grantor of a US revocable trust that holds a French rental property. She must file (a) Form 3520 Part II as the US owner of a grantor trust, (b) a substitute Form 3520-A because her trust has no US trustee, (c) Imprimé 2181-TRUST2 in France, and (d) her IFI return because the French property exceeds the €1.3 million threshold. All four filings run in parallel on staggered deadlines.

See our step-by-step Form 3520-A guide for line-by-line preparation. US owners should check Rev.Proc. 2020-17 eligibility before assuming any relief applies.

The distinction between Form 3520 France filing on the individual side and Form 3520-A on the trust side is the single most common error we correct at intake.

For US expats who set up a foreign grantor trust on the France side, both forms usually apply, and both usually require substitute-filer treatment because the trust has no US administrative footprint.

On the French settlor trust tax side, the same person carries French annual-reporting duties on 2181-TRUST2 and French income tax on the trust's income; the two systems land on one person, and it is easy to miss one.

FBAR and FATCA reporting for trust accounts in France

A US beneficiary of a French trust account may have an FBAR filing obligation even if they received no distributions during the year. FBAR reaches signature authority and beneficial interest, not just legal ownership.

If the aggregate of your foreign financial accounts (including any trust account with signature authority or a greater-than-50% beneficial interest) exceeds USD 10,000 at any point in the year, FinCEN Form 114 is required.

Form 8938 sits on top. FATCA reporting thresholds for single filers abroad are USD 200,000 at year-end or USD 300,000 at any point during the year (higher for married filing jointly).

For trust interests, Form 8938 requires reporting the maximum value of the trust interest during the year, which for grantor trusts is generally the value of the trust corpus.

France is a Model 1 FATCA partner. French financial institutions – including institutions holding trust accounts – report US account holders and specified US persons to the DGFiP, which transmits data to the IRS annually. This means undeclared trust accounts held in France are highly likely to surface through information exchange, not through voluntary disclosure.

Understand how FBAR reaches trust accounts held abroad for signature authority, filing mechanics, and common trust-account errors. For FATCA thresholds in full, check the IRS Form 8938 threshold guidance.

The FBAR trust requirements in France situation is worse when a French financial institution treats a trust account as a personal account of the trustee. In that case, the same account may need to be reported by the trustee, the settlor, and the beneficiary – three FBARs against a single balance.

Once trust income reporting on the France side is in view, the US side needs its own trace: distributions that were taxed in France still need to appear on US Form 3520 Part III and, where applicable, on the beneficiary's Form 1040 Schedule B.

FREE

Get a review of your trust reporting obligations.

Schedule a free intro consultation with us today

Schedule my free call

French trust penalties: what happens if you fail to report

The current French penalty structure is a flat €20,000 per missing declaration under Article 1736 IV bis CGI, plus a 1.5% sui generis levy under Article 990 J CGI on IFI-liable trust assets that were not properly declared (tax year 2025).

This replaced the 12.5% asset-based penalty struck down by the Conseil constitutionnel in decision 2016-618 QPC of 16 March 2017.

Even a single missed 2181-TRUST2 filing produces a €20,000 assessment that can exceed the annual income generated by the trust itself. The following table summarizes exposure on both sides for a US expat in France who fails to report.

The table below sets out the French and US penalty exposure for the three most common trust-reporting failures for tax year 2025.

 

The French tax office can also apply an 80% majoration under Article 1729-0 A CGI on any underlying tax reassessed following non-disclosure. On the US side, continuing failure to file Form 3520 after IRS notice can add USD 10,000 per 30-day period, up to the gross reportable amount.

 

 

Read our FATCA non-compliance penalty guide for US-side FATCA exposure in detail. For late Form 3520 penalty abatement paths, see our Form 3520 late-filing penalty abatement guide.

Grantor trust vs. non-grantor trust: French tax implications

France applies a look-through approach to both grantor and non-grantor trusts, effectively ignoring the trust as a separate taxpayer for income and wealth taxation. The US grantor/non-grantor distinction does not change the French outcome; it only changes which US filings are due.

For US expats, this is the core dual taxation trust France-US problem: France trust tax lands on the person, and US information reporting lands on the same person, and the two never fully coordinate.

Every US person French resident trust arrangement therefore needs both sides mapped before year-end, not at filing time.

For a grantor trust, French tax authorities look through to the US grantor. Trust income is taxed to the French-resident grantor annually whether or not distributed, and trust assets sit in the grantor's IFI base if they include French real estate. The grantor trust French tax result is that income appears on the grantor's French income tax return, categorised by source (dividends, interest, rental income, capital gains) as if the grantor held the assets directly.

For a non-grantor trust, French beneficiaries are taxed on distributions – as income under Article 120 CGI or as gifts under DMTG, depending on characterisation.

Undistributed income may still be attributed to a French-resident settlor under Article 123 bis CGI if the trust sits in a jurisdiction where the tax on that income is more than 40% lower than the tax that would apply in France – broadly, a foreign effective rate below 60% of the French rate (the 'régime fiscal privilégié' test under Article 238 A CGI).

An offshore trust French tax resident settlors hold therefore rarely delivers deferral: the anti-deferral rule pulls income back onto the French return.

Irrevocable trust France outcome: where the settlor has genuinely divested, trust income is not attributed to them under Article 123 bis provided the trust jurisdiction is not low-tax; distributions to French-resident beneficiaries are then taxed at the beneficiary level.

Non-grantor status on the US side does not by itself deliver this French outcome – the substance test under Article 123 bis is what matters. A US revocable living trust is almost always treated as a grantor trust by France, since the settlor's continuing power to revoke leaves the assets under their control.

This matches the US grantor-trust classification, but it does not exempt the trust from French declaration – transparency for income tax does not remove the Article 1649 AB reporting duty.

Our foreign assets disclosure guide covers the reporting overlay.

US-France tax treaty and trust provisions: what the treaty does (and does not) cover

The 1994 US-France tax treaty is largely silent on trusts, leaving cross-border trust taxation governed almost entirely by domestic French and US rules. The treaty contains no dedicated trust article, and neither the technical explanations nor subsequent protocols closed the gap.

Treaty benefits on dividends (reduced to 15% or 5% depending on ownership), interest (0%), and royalties (0%) may not flow through to trust beneficiaries unless the trust qualifies as a resident of one contracting state.

The Limitation on Benefits (LOB) article in the treaty is often the barrier: trust structures without a substantive economic connection to one state or the other frequently fail LOB and lose treaty relief. For US expats, the practical result is that treaty relief usually attaches to income you receive personally – wages, interest on your own accounts, dividends held individually – but does not automatically follow through a foreign trust.

For US-France tax treaty trust provisions, expect no shortcut: each item of trust income must be traced to the eventual taxpayer and analysed under the treaty article that fits that character. The US trust France taxation outcome usually rests on domestic law of each state, mitigated only where the taxpayer (not the trust) can claim treaty relief on their own share.

For broader planning context, see our guide to the best investment options for American expatriates.

Revocable living trust in France: special considerations for US expats

A US revocable living trust does not avoid French succession law or French inheritance tax on French-situs assets. France does not recognise the trust as owning the property; it treats the settlor as owner during life and applies DMTG on death regardless of trust terms.

The following five considerations apply to any US revocable trust held by a French tax resident:

1. Transparent for income tax. All trust income is taxed to the settlor annually on the French income tax return.
2. Included in the French succession estate. Trust assets held on death sit in the settlor's estate for DMTG purposes.
3. Annual declaration required. The trust must be declared on Imprimé 2181-TRUST2 by 15 June each year.
4. Forced heirship is not automatic. French courts generally respect a foreign trust or will that departs from the réserve héréditaire for French-situs assets, unless the deceased or a child is an EU national or resident and the foreign law provides no equivalent protection – only then does a limited clawback apply under Civil Code Article 913, paragraph 3.
5. Pour-over wills have no legal effect on French-situs property. French succession must be settled through a French notaire, not through the US trust administration.

The revocable trust France taxation outcome surprises many US expats who assumed the trust would sidestep French probate. It does not.

On the settlor's death, French tax law creates a trust deemed constituent France position: the beneficiary who is treated as receiving the trust corpus stands in the settlor's shoes for future French filing and IFI purposes.

For families weighing US planning tools that also affect financial-aid calculations, our guide on FEIE and FAFSA interactions for expat families covers the parallel US-side planning issues.

Catch-up filing and voluntary disclosure for unreported French trusts

If you have not previously reported a French trust or a US trust that touches France, the following three catch-up paths are the standard options:

1. Streamlined Foreign Offshore Procedures (SFOP) – available to non-willful violators who meet the non-residency requirement (physical presence outside the US at least 330 full days in one of the three most recent years). Covers 3 years of amended returns and 6 years of FBARs. 0% offshore penalty, though tax and interest are due.
2. Delinquent International Information Return Submission Procedures – for late Forms 3520 and 3520-A where there is no unreported income and reasonable cause can be shown. No penalty if reasonable cause is accepted.
3. IRS Voluntary Disclosure Practice via Form 14457 – for potentially willful violations. Provides protection from criminal referral but includes a substantial civil-penalty framework.

Based on our client scenario at TFX: a US citizen in Paris failed to report a UK family trust that made distributions to her over five years. Because she met the non-residency test and the omission was non-willful, she used SFOP to file three years of amended returns and six years of FBARs. Result: no offshore penalty, back tax, and interest paid on the previously unreported distribution income.

For French trust compliance where the missed filing is on the French side rather than the US side, coordinate with a French avocat: French remedial procedures differ from US streamlined relief and are outside our US-focused scope.

Get back to compliance with Streamlined Filing Procedures

If you have missed Form 3520, Form 3520-A, or FBAR filings tied to a French trust, the Streamlined Procedures are usually the fastest path back to compliance – 0% offshore penalty for non-willful cases where you meet the non-residency test.

Let us get you back to compliance through the IRS streamlined program.

Review my streamlined options

French trust compliance checklist for US expats: tax year 2025 [tax year 2026]

Missing even one of these eight deadlines can trigger penalties on both sides of the Atlantic simultaneously. As of August 2026, several tax year 2025 deadlines have already passed; the still-open windows and the forward calendar for tax year 2026 [filed in 2027] are noted alongside.

The following eight action items are the standard trust compliance path for a US expat in France:

1. Determine your French tax residence (183-day rule, principal home in France, or centre of economic interests under Article 4B CGI). Ongoing – applies year-round.
2. Identify every trust in which you are settlor, trustee, or beneficiary, including US revocable living trusts. Ongoing.
3. File Imprimé 2181-TRUST2 – tax year 2025 deadline was 15 June 2026 (passed). Tax year 2026 deadline: 15 June 2027. If the tax year 2025 filing was missed, the Streamlined path does not apply (US-only); the correction must go through a French avocat fiscaliste.
4. File Form 3520 – the tax year 2025 deadline was 15 April 2026, extended to 15 October 2026 (still open with a valid Form 4868 or Form 2350 extension in place). Tax year 2026 deadlines: 15 April 2027 / 15 October 2027.
5. File Form 3520-A – tax year 2025 deadline was 15 March 2026 (passed); extension available via Form 7004 to 15 September 2026 if filed timely. Tax year 2026 deadline: 15 March 2027.
6. File FinCEN Form 114 (FBAR) – tax year 2025 deadline was 15 April 2026, with automatic extension to 15 October 2026 (still open). Tax year 2026 deadline: 15 April 2027 / 15 October 2027 auto-extended.
7. Report trust-held French real estate on Form 2042-IFI if French real estate exceeds €1.3 million net – filed with the income tax return in spring; tax year 2025 deadline passed. Tax year 2026 deadline: spring 2027.
8. Confirm treaty position for any trust income subject to withholding, and document your grantor/non-grantor determination in writing before year-end.

If tax year 2025 US filings were missed and the case is non-willful, Streamlined Foreign Offshore Procedures typically bring the file current with no offshore penalty.

See our FATCA reporting exemptions guide for accounts and interests that may be outside FATCA scope from the outset.

French beneficiary reporting: when you receive a trust distribution in France

French tax authorities can reclassify a trust distribution as a taxable gift subject to DMTG at rates up to 60% if the beneficiary-settlor relationship is unclear or the trustee sits in a non-cooperative jurisdiction. The reporting duty falls on the beneficiary, not the trustee, once the distribution is received.

A French tax resident who receives a foreign trust distribution must:

• Report the distribution on the French income tax return, using Formulaire 2047 for foreign-source income where the distribution is characterised as trust income.
• Determine whether the distribution is characterised as income (taxed at the progressive scale up to 45%) or as a gift/inheritance (DMTG, at rates set by the settlor-beneficiary relationship).
• Report the distribution on Form 3520 Part III if the beneficiary is a US person.
• Consider whether the distribution reduces the trust's French-reportable asset base for the following year's 2181-TRUST2.

The characterisation step is where French beneficiary trust reporting most often goes wrong. Distributions that look like a bequest on the trust deed can be reclassified as ordinary income if the trust income was accumulated inside the trust and paid out on the same event.

Our reference on tax reporting guidelines for foreign income explains the parallel US treatment.

Work with a US tax specialist who understands trust-related France exposure

Trust distributions in France sit at the intersection of French DMTG rules and US foreign trust reporting.

We prepare the US filings – Forms 3520, 3520-A, FBAR, 8938 – and coordinate with your French tax counsel on the 2181-TRUST forms and IFI position, so nothing falls between the two sides.

Get started today