Cross-border tax counsel for American families moving to France
Residency, trusts, estate and inheritance planning, and the France-U.S. treaty. Planned before you move, handled once you are here.
A boutique French tax practice built for American families
Thomas Dubanchet — French tax lawyer, Nice Bar.
Relocating to France is never only a lifestyle decision. It is a tax decision. French tax residency triggers worldwide reporting, French taxation on most categories of income, and interaction with the France–U.S. income tax treaty that is neither obvious nor forgiving. American families who miss the tax layer of their move pay for it for years.
Bespoke Tax is a Nice-based boutique founded by Thomas Dubanchet, a French tax lawyer admitted to the Nice Bar, with prior experience in Paris, Monaco and the French Riviera. The practice focuses exclusively on American families — U.S. citizens and dual U.S./French nationals — who are planning to move to France or who already live here.
We advise on the full arc of the move:
French tax residency analysis and treaty tie-breaker positioning
Structuring of income, investments, and real estate before arrival
French taxation of dividends, interest, capital gains, rental income, and pensions under the France–U.S. treaty
Trust reporting, trust regularization, and trust-related French tax exposure (Form 2181-Trust, Article 792-0 bis CGI)
Real estate acquisitions, SCI and usufruit structures, IFI (wealth tax on real estate)
Estate planning and French wills for American families with French property
Assistance with French tax audits and tax rulings
Everything we produce is written in English, grounded in French tax law, and designed to be read by sophisticated American clients and their U.S. advisors.
How We Help You
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When things get complex
▸ Rescrits fiscaux — binding advance tax rulings on residency, trust status, or structures
▸ Assistance and representation in French tax audits
▸ Estate planning and French wills for U.S. citizens with French assets
▸ Cross-border gift and inheritance tax analysis under the 1978 estate treaty -
Before your move
▸ French tax residency analysis under domestic law and the France–U.S. treaty
▸ Pre-arrival structuring of U.S. income, investments, and retirement accounts
▸ Trust review and regularization before French residency is triggered
▸ Real estate acquisition planning — direct, SCI, or with usufruit -
Once you are here
▸ French tax return preparation and annual compliance
▸ Treaty positioning on dividends, interest, capital gains, rental income, pensions
▸ Wealth tax (IFI) strategy for French and foreign real estate
▸ Trust reporting (Form 2181-Trust) and coordination with U.S. trustees
Client testimonials
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![Five golden stars in a row]()
The engagement covered French tax residency analysis under the France-U.S. treaty, treatment of U.S. LLC income, and annual compliance. A tax ruling was obtained on the residency position.
A U.S. entrepreneur working remotely from France. -
![Five gold stars in a row representing a five-star rating.]()
The engagement covered French wealth tax (IFI) optimization, rental income reporting under the France-U.S. treaty, and an estate planning review including a French will for the French based real estate.
A U.S. retireee with a second home in Provence.
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![Five yellow stars in a row on a transparent background.]()
The engagement covered pre-arrival residency positioning, trust regularization, and acquisition of a French primary residence through a tailored structure. The work was coordinated with their U.S. estate planning attorney and CPA.
A U.S. family relocating to the French Riviera
Your French tax counsel for American families in France
Every American family's move to France is different. The tax issues, however, are not, they follow a predictable structure that can be planned, documented, and made tax-efficient. We help you do exactly that, before the move, during the move, and for as long as your family remains connected to France.
