Expat in France : Reporting your foreign accounts (form 3916)
It’s 10:30 at night, you’ve worked your way through 15 pages of French tax forms online and three cups of coffee. You can just feel the tantalizing end to this year’s tax misery when, upon clicking on that semi-final “suivant”, you are asked just how many foreign accounts you would like to report.
If you are like every other American over the age of 25, this number could be anywhere from 8 to 45. And you need to fill out one of these forms separately for each one. How do you proceed?
Let’s go over a few basic facts about what you need to report, how to report it, and best of all, how to do it as painlessly as possible.
Preparation is key
At the risk of sounding like someone’s grandmother, you will thank yourself for doing a few things in advance (even if it means closing the Déclaration form window for the night and coming back to it).
The first thing we are going to do is to make a list of all of the account you will need to report. Obviously, these include bank accounts – savings and checking. It also includes investment accounts – regular brokerage accounts, but also CD’s, separate money market accounts and retirement accounts.
Credit and store credit cards do not feel like accounts to us, but too many tax opinions in France have said they are. To be safe, include them (a nice reminder to close that Gap account from 1998).
Payment and money transfer accounts like PayPal and Wise should only be reported if you are moving at least 10,000 EUR through them during the year.
Digital asset accounts (i.e. crypto) need to be listed.
And last but not least, your life insurance policies are likely “accounts,” as well. A simple Term policy should be the exception, but as I have not found written confirmation of that, I include them.
Think long-term
You are going to have to do this annually. So instead of filling these in right away, make a list on your computer. We are typing so that you can cut and paste this year and forever more. By the way, be sure to use the French format for dates “dd/mm/yyyy” to avoid retyping.
1. For each bank account, investment account, or payment/transfer account over the transfer limit for the year, dig through your records and type out the following information:
a. The person whose name is on the account (if it’s a joint account of two adults in the household, you can choose randomly);
b. Account number (if it doesn’t have one, use “11111”);
c. Type of account: choose among “checking”, “savings” if it’s a bank account and use “other”;
d. The date the account was opened (I know, make your best guess, if necessary);
e. If you closed the account during the year, the date it was closed;
f. The name of the bank;
g. The address of the bank – leave out the commas in the address and the “US”;
h. Note if you use this account for a business activity.
2. For each digital asset account (compte d’actifs numériques):
a. Person whose name is on the account;
b. Account number or email address you’ve associated with the account;
c. Type of account: use “numérique” or digital if you are avoiding accents;
d. The date the account was opened (I know, make your best guess, if necessary);
e. If you closed the account during the year, the date it was closed;
f. Now see if the institution that holds your assets is on the list at the bottom of the page. If so, note the code (i.e. “Binance, 001”);
g. If it’s not on the list, note the name and address of the institution, or if it doesn’t use a physical address, the URL for its website);
h. Note if you use this account for business.
3. For each life insurance policy (« contrat de capitalisation ou placement de même nature »), list the following (tip: you can find this on the cover sheet of your contract or a bill for premiums):
a. The name of the insurance product, i.e. “term life” or “variable annuity”;
b. The policy number;
c. Indicate if your policy is just a term policy or is something else. For those of you not fascinated by insurance products, a term life insurance policy does nothing but pay someone a lump sum when you die if you give the company the premium amount they’ve asked for. All other common insurance products have a term policy built alongside some sort of investment style feature. So, if your policy pays out an annuity, has a “guaranteed rate”, has premiums that change annually, or mentions investment, it qualifies as “not a term policy”;
d. The name of the insurance company;
e. The address of the insurance company (again, no commas);
f. The date the policy started;
g. The term of the policy, after which the contract ends (i.e. 10 years);
h. Did you sign any amendments to the policy during the year? If so, note the dates;
i. Did you cash in any part of this policy during the year? If so, note dates and amounts;
j. Did you pay any premiums during the year? If so, total them up, convert to EUR and note the amount (*you might want to use the 1 USD = .933 rate for multiple transactions during the year 2024; it’s the average from the Bank of France records);
k. The “cash out” and “death benefit” amounts (you likely only have the latter for a term policy).
Back to the forms
You now have everything you need to fill out your forms. Go through your online Déclaration to indicate the total number of accounts you will be reporting. The software gives you a form for each account. If you forget one or have an extra, you can delete or add later.
You will now use the magic of cut and paste to fill out all of these forms one at a time.
Six tips to avoid confusion
1. Skip section 1, where the form asks if you are « une personne physique agissant en qualité d’exploitant d’une activité donnant lieu à déclaration spécifique de résultats ». Unless you are filling out these forms under contract for the actual account holder, the answer is always “no.” You also are not a “personne morale”, which would be a corporation or partnership of some sort.
2. Section 2 is where you choose “compte bancaire” for everything that is not either a crypto-type account (“compte d’actifs numériques”) or an insurance policy “contrat de capitalisation ou…”. Also, you will never have a contrat de capitalisation in the US.
3. A compte courant is any sort of checking account. A compte d’épargne is a savings account. All of the other comptes bancaires are “others” (“Autres”).
4. The Désignation de l’organisme gestionnaire du compte is a long way of saying, “the name of the bank.”
5. A procuration is a form of power of attorney. If you are just the power of attorney for anyone on these accounts, check the box in section 3.2 (“Bénéficiaire d’une procuration…”). If not, the other box, “Titulaire en propre” ALWAYS applies to you.
6. If you use any of these accounts for your business activity, use section 5 to indicate that you use it just for business or for both “usage mixte.” This might come up if you do freelancing in the US and keep a credit card just for that venture. If this applies to you, you will need to give the name and address of the business. Fill in “11111” if you don’t have a SIRET.
Keep, Repeat, Delete
Unless the technology for these Déclarations changes (and it does regularly), you need to retype these forms every year. Keep this list in a “tax” folder where you can find it next spring and make any adjustments as needed.
And finally, if you find yourself wondering why you still have some of these accounts, go ahead and close them. You will have to report them for the year they were closed, but you can delete and shorten the list over the years.
Good luck!