The movement of talent between France and the United States has grown steadily over the past decade. Whether it’s a French company expanding to the U.S., or an American multinational relocating executives to Paris, global mobility has become a central part of international business strategy. Yet, behind every expatriation or impatriation lies a complex network of tax, social, and administrative considerations that require careful planning.
1. Beyond relocation — understanding “mobility strategy”
Moving employees across borders is no longer limited to visa applications and logistics. Today, global mobility involves an integrated strategy that balances fiscal efficiency, employee well-being, and regulatory compliance.
A poorly structured assignment can lead to double taxation, loss of social security benefits, or unexpected corporate costs. Conversely, a well-planned transfer can create both individual and corporate advantages, optimizing the tax burden on both sides of the Atlantic.
2. Tax residency and treaty protection
One of the first questions companies and employees must address is tax residency. The France–U.S. tax treaty provides mechanisms to avoid double taxation, but these depend on each person’s specific situation — duration of stay, center of economic interests, and employment structure. Understanding when a U.S. assignee becomes a French tax resident (or vice versa) is crucial for determining where income, bonuses, and equity compensation will be taxed.
Assignments that are not properly coordinated can result in double reporting obligations — to the IRS and to the French tax authorities — or in missed opportunities for treaty relief. Early planning allows companies to manage payroll efficiently and avoid unnecessary compliance issues.
3. Social security and totalization agreements
In addition to taxes, social security coverage can be a major pain point. Fortunately, France and the U.S. have signed a Totalization Agreement that helps employees avoid dual contributions. However, eligibility for continued coverage under the home-country system depends on several factors, including the nature and duration of the assignment. Employers need to determine whether Form SE 404 (for U.S. coverage) or Form SE 401 (for French coverage) applies, and whether complementary health and retirement benefits need to be coordinated.
4. Repatriation: the often-forgotten stage
When an assignment ends, many companies underestimate the complexity of repatriation. Returning employees may face capital gains on stock options, the need to unwind 401(k) or PER accounts, or challenges transferring pensions between systems. Proper coordination at this stage ensures that income earned abroad is correctly reported and that credits or exclusions (such as the Foreign Earned Income Exclusion or foreign tax credits) are applied correctly.
5. Why proactive collaboration matters
Successful mobility programs rely on collaboration between HR, payroll, and tax departments, supported by advisors who understand both jurisdictions. A proactive approach avoids reactive problem-solving and reduces the cost of compliance. With increasingly mobile workforces — and the rise of remote or hybrid assignments — clarity around where work is performed and taxed has never been more important.
At Expand CPA, our team of U.S. CPAs and French Experts-Comptables supports companies and individuals on both sides of the Atlantic in designing effective, compliant mobility strategies. Our role is to simplify the complexity of cross-border taxation and allow companies to focus on what truly matters: their people and their growth.
In summary:
Managing global mobility between France and the U.S. is not just a compliance exercise — it’s a strategic process that impacts talent retention, cost efficiency, and corporate reputation. With the right planning, companies can turn what feels like a regulatory challenge into a genuine competitive advantage.
Expand CPA is a cross-border accounting and advisory firm specializing in U.S. and French tax services for individuals, entrepreneurs, and companies operating internationally. With offices in Paris, Tel Aviv, and New York, we assist clients who live, work, or invest across borders — ensuring full compliance while optimizing their global tax position.
Our team combines the expertise of French Experts-Comptables and U.S. CPAs, providing integrated support that covers both jurisdictions. We work with a diverse clientele:
– Private clients (Americans in France, French citizens with U.S. income, dual nationals)
– Startups and SMEs expanding internationally
– Corporate groups with cross-border payroll, mobility, and reporting needs
We pride ourselves on a modern, collaborative, and human approach, blending deep technical expertise with a strong understanding of international clients’ lifestyles and professional realities.
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