- Tax

Year-End Planning for Americans in France 2026: What You Need to Do Before December 31

If you are an American living in France, December 31 is not just the end of the calendar year. It is the simultaneous close of your US tax year and your French tax year, each with its own hard deadlines, each with consequences for the other. The decisions that must be made before that date, and the order in which they are made, directly affect your income tax on both sides of the Atlantic, your Medicare premiums two years from now, your French wealth tax bill in January, and the long-run efficiency of your retirement income.

This guide covers every material year-end action for Americans in France in 2026: what it is, why it matters, what happens if you miss it, and, crucially, who is the right person to help you with it. The planning decisions covered here, sizing a Roth conversion, managing your IFI position, sequencing withdrawals across income brackets, using your assurance vie annual allowance, are financial planning decisions. They belong in a conversation with a financial adviser who understands both countries. The actual filing of your tax returns, in the US and in France, is a separate job for your qualified tax professionals on each side. This article draws that line clearly throughout.

Our US Citizens in France service page explains how we work with Americans at every stage of financial planning in France.

December 31 Hard Deadlines: Americans in France

US side: RMD taken • Roth conversion settled • Tax-loss harvesting complete • QCDs completed

French side: IFI real estate position managed • Assurance vie annual allowance used • Gifting decisions completed

Both: Income managed for IRMAA lookback • French bracket interaction modelled • Beneficiary designations reviewed

US Deadlines: The Actions That Cannot Be Carried Forward

Required Minimum Distributions: December 31, No Exceptions

If you are 73 or older and hold a Traditional IRA, 401(k), 403(b), an inherited IRA, or most other pre-tax retirement accounts, your Required Minimum Distribution for 2026 must be taken by December 31, 2026. Living in France does not extend this deadline. There is no overseas exception. Missing an RMD triggers an IRS excise tax of 25 percent on the shortfall amount. Correcting it within two years reduces the penalty to 10 percent, but the cost is entirely avoidable with advance planning.

If you are turning 73 in 2026, you have a one-time option to delay your first RMD until April 1, 2027. The catch is that delaying means two RMDs fall in the same calendar year: the delayed first and the normal second. Two large distributions stacked in 2027 can push you into a higher US bracket, a higher French bracket through the taux effectif mechanism, and potentially above an IRMAA threshold that will affect your Medicare premiums in 2029. A financial adviser can model whether taking your first RMD in December 2026 or deferring to April 2027 produces the better outcome across both systems.

Time zone note: the RMD deadline is December 31 US time. France is six to nine hours ahead. Allow processing time and target early-to-mid December for your distribution rather than the final days of the month. Many custodians have internal year-end processing cutoffs earlier than December 31.

Roth Conversions: The Most Valuable Year-End Decision in France

A Roth conversion, converting pre-tax IRA or 401(k) money to a Roth IRA and paying income tax on the amount now, must be executed and settled by December 31 to count in the 2026 tax year. There is no extension.

Roth conversions can be a powerful tool for Americans in France, though the tax treatment requires careful attention. Under the France–U.S. treaty framework, Roth IRA distributions may receive favorable treatment; however, the analysis is nuanced. Qualified Roth withdrawals are generally not subject to U.S. federal income tax, but their interaction with the French system is not always “tax-free in practice.” In particular, French authorities may incorporate such amounts into the taux effectif (effective rate) computation, which can affect the tax rate applied to your other French-taxable income. Given these complexities, Roth conversions should be evaluated based on your specific tax profile, conversion timing, and total income rather than assuming a universal outcome.

Sizing the 2026 conversion correctly requires knowing your total projected income across both tax systems. The conversion adds to your US federal taxable income. It is also declared on your French return through the taux effectif mechanism, where it can affect the rate applied to your French-taxable income even without directly generating a French tax bill. It interacts with your RMD level. It affects your IRMAA position in 2028. There are at least four variables that move simultaneously when you change the conversion amount, and none of them are visible in a standard US bracket calculator. A financial adviser who can model both sides before December 31 is the right person to determine the optimal size, not an online tool built for domestic filers.

IRMAA: Why 2026 Income Affects Your 2028 Medicare Premiums

Medicare Part B and Part D premiums are means-tested through the Income-Related Monthly Adjustment Amount (IRMAA), calculated on income from two years prior. This means your 2026 income, including any Roth conversion, RMD, capital gain, or other large one-time item, directly determines your Medicare costs in 2028. The IRMAA surcharge begins for single filers with MAGI above $106,000 and for married couples above $212,000. Each tier above the threshold adds a meaningful monthly surcharge to both Part B and Part D.

Critically, not all income counts toward IRMAA MAGI in the same way. Qualified Roth IRA distributions do not count. Traditional IRA withdrawals and Roth conversions do. Tax-exempt interest does count, which surprises many people. This means that the composition of your 2026 income, not just the total level, affects whether you cross an IRMAA threshold. Modelling this correctly before December 31 is the kind of year-end financial planning work that directly reduces your costs in a future year. It belongs with your financial adviser, not your tax preparer.

Qualified Charitable Distributions: Tax-Free and RMD-Counting

If you are 70½ or older, you can direct up to $100,000 directly from your Traditional IRA to a qualified charity as a Qualified Charitable Distribution (QCD) before December 31. A QCD counts toward your RMD for the year but is excluded from your taxable income entirely, unlike a regular withdrawal followed by a charitable deduction. For Americans in France with charitable intentions and RMD pressure, this is a straightforward way to reduce your taxable income for the year. The distribution must be paid directly from the IRA to the charity, not to you first.

Tax-Loss Harvesting in US Taxable Accounts

If you hold investments in a US taxable brokerage account that have declined in value since purchase, selling them before December 31 realizes a capital loss that can offset capital gains elsewhere in the portfolio or, up to $3,000, ordinary income. This must be executed before year-end. The wash-sale rule prevents buying substantially identical securities within 30 days before or after the sale, so the replacement investment needs to be planned as part of the execution.

The decision about which positions to harvest, and how to restructure the portfolio around the sale, is a financial planning and investment decision. The reporting of the gain or loss on both your US and French returns is a job for your tax professionals. A financial adviser who knows your full portfolio across both countries identifies which harvesting opportunities make sense in the context of your overall strategy.

French Deadlines: What Must Be Done Before the January 1 IFI Snapshot

The IFI Assessment Date: January 1 Is Actually December 31

The French wealth tax on real estate, the Impot sur la Fortune Immobiliere, is assessed on the net value of your taxable real estate as of January 1 of each year. In practical terms, December 31 is your last opportunity to affect your IFI position for the 2027 assessment. Any action that reduces your net real estate value, or increases your deductible liabilities, must be completed before midnight on December 31.

A critical detail that many Americans discover too late: if your net real estate crosses EUR 1.3 million, the IFI does not apply only on the excess above that threshold. It applies retroactively from EUR 800,000, because the rate table starts there. Crossing the threshold by even EUR 1 generates a tax bill on the entire EUR 500,000 band from EUR 800,000 to EUR 1.3 million. For portfolios sitting close to this boundary, the January 1 snapshot matters enormously. A financial adviser who works with French-resident clients can model your likely January 1 IFI position now, and identify whether any action before year-end produces a meaningful net benefit.

Year-End IFI Actions Worth Reviewing

  • Portfolio rebalancing toward financial assets: equities, bonds, and investment funds are entirely excluded from the IFI base. If you have liquid capital and have been considering reducing real estate concentration, year-end is a natural moment to rebalance before the January 1 snapshot.
  • Outstanding mortgage debt: the IFI allows deduction of outstanding mortgage balances on relevant real estate. Ensure your lender’s year-end balance reporting reflects the correct figure.
  • Property gifting: a property gift completed before December 31 removes the asset from your January 1 IFI base. Gift tax analysis and notaire fees apply, and the IFI saving must be weighed against these costs. This is a financial planning conversation, not a DIY decision.
  • Primary residence status: the 30 percent IFI reduction on your principal residence applies only if it is your primary residence on January 1. Any change in residence designation should be confirmed before year-end.

For the full mechanics of the IFI calculation and the longer-term portfolio diversification strategy, see our French Wealth Tax (IFI) guide.

Assurance Vie: Use Your Annual Allowance or Lose It

If you hold a French assurance vie policy that has been open for more than eight years, withdrawals benefit from an annual tax-free allowance applied against the gains portion: EUR 4,600 for single filers, EUR 9,200 for couples. This allowance does not carry over. Unused allowance from 2026 cannot be added to 2027. If you do not make a withdrawal before December 31, the 2026 allowance is permanently lost.

Whether it makes sense to take a withdrawal to use the 2026 allowance depends on your total income picture for the year. A financial adviser can model whether using the allowance now or deferring to a lower-income year produces the better after-tax outcome. Note that French domestic assurance vie is generally not available to US citizens due to FATCA complications. If you hold an international equivalent, please be aware that withdrawals are generally taxable in the US. You should work with a financial adviser to model the specific US tax liability of any withdrawal as part of your planning.

French Lifetime Gifting Allowances

Each parent can gift EUR 100,000 per child every 15 years free of French gift tax. A cash gift of up to EUR 31,865 to a child, grandchild, or great-grandchild aged 18 or over is also available on the same 15-year reset. Gifts of real estate completed before December 31 serve a dual purpose: they reduce your January 1 IFI base and progressively reduce future inheritance tax exposure. The cost is notaire fees and a detailed gift tax analysis, both of which should be assessed with professional guidance before execution.

From the US side, the annual gift tax exclusion for 2026 is $19,000 per recipient, with a separate exclusion of $190,000 for gifts to a non-US-citizen spouse. Gifts above the annual exclusion require a Form 709 filing. The French and US gift dimensions of any gifting decision should be reviewed together.

The Interaction Problem: Why Order Matters

This is the section that most clearly explains why year-end cross-border planning for Americans in France is not a checklist but a sequencing exercise. Each decision affects the inputs for the next one.

  • Roth conversion and French taux effectif: the conversion adds to your declared income on the French return and can lift the effective rate applied to your French-taxable income. Size the conversion with this effect visible, not invisibly embedded.
  • RMD and IRMAA 2028: taking more than the minimum RMD to use a lower US bracket may push your MAGI above an IRMAA tier. The IRMAA model and the conversion model need to run simultaneously.
  • Capital gains and French bracket: capital gains realized in a US taxable account are declared on the French return. A large gain that looked manageable in a US context may push your total declared income into a higher French bracket.
  • IFI portfolio rebalancing and investment returns: selling a real estate holding or rebalancing toward financial assets to reduce IFI exposure also changes your investment return profile and potentially your income from those assets in future years. The IFI planning and the investment strategy are not separate conversations.
The right sequence: estimate total 2026 income across both returns first. Identify the binding constraints: IRMAA threshold, French bracket boundary, IFI snapshot position. Then size the Roth conversion and RMD. Then overlay the assurance vie withdrawal and gifting decisions. Every step changes the inputs for the next. This calculation belongs with a financial adviser in October or November, not in the last week of December when options are already narrowing.
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Americans in France: Year-End 2026 Action Checklist

ActionHard DeadlineConsequence of MissingWho Manages It
Take RMD (age 73+)December 3125% IRS excise tax on shortfallFinancial adviser models size and timing; custodian executes
Execute Roth conversionDecember 31Counts in 2027; window may be less favorableFinancial adviser sizes and sequences; custodian executes
Manage income below IRMAA thresholdDecember 31Higher Medicare premiums in 2028Financial adviser models MAGI across all income sources
Complete Qualified Charitable DistributionDecember 312026 QCD opportunity lost permanentlyFinancial adviser confirms strategy; custodian directs to charity
Tax-loss harvesting in US accountsDecember 31Losses cannot offset 2026 gainsFinancial adviser identifies opportunities; tax professional reports
Review and manage IFI real estate positionDecember 31Full 2027 IFI on January 1 valueFinancial adviser models position; notaire/tax adviser for execution
Use assurance vie annual allowanceDecember 31EUR 4,600 / EUR 9,200 permanently lostFinancial adviser models whether and how much to withdraw
French lifetime gifting (if appropriate)No fixed annual deadlineSuccession tax paid instead of gift allowance usedFinancial adviser models benefit; notaire executes
US annual gift exclusion ($19k/recipient)December 31Exclusion lost; cannot carry forwardFinancial adviser confirms strategy; tax professional for Form 709
Review beneficiary designationsNo deadline, best done annuallyAssets route to wrong person or jurisdictionFinancial adviser coordinates as part of annual review

This table is a planning framework, not a comprehensive compliance guide. Individual applicability depends on your specific accounts, residency status, and financial position. Please work through each item with a qualified financial adviser and your tax professionals in both jurisdictions.

FAQs – Year-End Planning for Americans in France 2026

I live in France. Does my RMD deadline change?

No. The December 31 deadline is based on US time, not French time. France is six to nine hours ahead of the US, so allow processing time and aim to have your distribution settled by mid-December rather than the final days of the month. Some custodians have internal year-end cutoffs earlier than December 31.

Can I do a Roth conversion after December 31 and apply it to 2026?

No. A Roth conversion must be completed and settled in the calendar year for which it counts. A conversion executed on January 2, 2027 counts in 2027, not 2026. There is no extension for conversions as there is for certain IRA contributions.

Why does my Roth conversion affect my French tax return?

France uses a method called the taux effectif to tax French residents with treaty-protected foreign income. Even though your Roth conversion is not directly taxable in France under the treaty, France includes it in the total declared income used to calculate the effective tax rate applied to your French-taxable income. A large Roth conversion can therefore push your effective French rate higher, increasing the tax on your French-taxable income sources. This is not a reason to avoid conversions. It is a reason to size them carefully with a financial adviser who can model both tax systems simultaneously.

What if I have never used my assurance vie annual allowance?

The EUR 4,600 or EUR 9,200 annual allowance applies to each calendar year independently and does not accumulate. If you held an assurance vie for eight years but never made a withdrawal, you have not accumulated eight years of allowances. Each year’s allowance either gets used through a withdrawal in that year or is permanently lost. If your policy is over eight years old and you have never made a withdrawal, a conversation with your financial adviser about whether and when to use the 2026 allowance is worth having before December 31.

Does Harrison Brook help with US tax returns or French tax filings?

No. Harrison Brook USA is a financial planning and investment advisory firm. We focus on the planning and investment decisions: sizing Roth conversions, modelling income against IRMAA thresholds and French brackets, managing IFI exposure, and coordinating withdrawal sequences. The filing of your US returns is handled by a qualified US expat CPA, and your French return by a French tax adviser. We coordinate with both professionals as part of providing joined-up financial planning, but the tax compliance filings are theirs to prepare.

Year-End Planning for Americans in France Needs Two Frameworks at Once.

Harrison Brook USA works with Americans in France to model the right sequence of year-end decisions across both tax systems before December 31.

Book your year-end planning consultation today.
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Disclaimer: This article is for informational purposes only and does not constitute financial, tax, or legal advice. Tax rules, deadlines, allowances, and thresholds in the United States and France change frequently and individual circumstances vary. Figures cited reflect 2026 published parameters. Harrison Brook USA is a financial planning and investment advisory firm and does not provide tax preparation or tax advisory services. Please consult a qualified cross-border financial adviser for financial planning guidance and qualified tax professionals in each relevant jurisdiction for compliance matters.

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