I'm a French tax resident with a US LLC — am I taxed in France on LLC profits?

French tax residents are subject to French income tax on their worldwide income. The income of a US single-member LLC owned by a French resident may be treated as 'bénéfices industriels et commerciaux' (BIC) or 'revenus de capitaux mobiliers' depending on the French classification of the LLC. The US-France treaty and foreign tax credit provisions may reduce double taxation. Consult a French expert-comptable (chartered accountant) with US experience.

How does France classify a US single-member LLC?

France applies a 'comparability analysis' to foreign entities (the so-called 'Quéméner' doctrine from the French Supreme Court). A US single-member LLC is typically classified as a 'société de personnes' (transparent entity) or an 'opaque' corporate entity depending on its US tax treatment and the comparison with equivalent French entities. The French classification affects how LLC income is taxed in France. French tax advice is essential.

Does France's ISF/IFI wealth tax apply to my US LLC?

France abolished its ISF (Impôt de Solidarité sur la Fortune) in 2018 and replaced it with the IFI (Impôt sur la Fortune Immobilière), which applies only to real estate assets. If your US LLC holds real estate, the IFI may apply to French residents on their share of the LLC's real estate value. If the LLC holds no real estate, IFI generally does not apply.

Can I use my numéro fiscal (French tax ID) on Form 5472?

No. Your French numéro fiscal (numéro d'identification fiscal) is not accepted by the IRS as a US taxpayer identification number. You need a US ITIN (for individuals) or EIN (for French companies) for Form 5472. Apply via IRS Form W-7 using your French passport.

My French SAS owns the US LLC — who files Form 5472?

The U.S. entity's classification, ownership, and related-party transaction facts determine whether Form 5472 is required and how a French SAS is reported. Management fees, loans, royalties, and contributions should be evaluated under the current reportable-transaction rules rather than assumed to be reportable in every case.

Form5472.ai

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Form 5472 for French LLC Owners

French entrepreneurs and SAS/SARL owners with U.S. LLCs can review when Form 5472 may apply, plus U.S.-France entity and treaty considerations.

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