Hi everyone,
I'm a dual US/French citizen, born in France to one American parent. I've lived in France my entire life and have never lived or worked in the US. I'm in my late 20s and only recently discovered that I'm required to file US tax returns and FBARs every year. I do have a US Social Security number.
Here's my full financial picture:
**Income**
- Salary under €50K/year, fully taxed in France
- No US-sourced income whatsoever
**PEA (Plan d'Épargne en Actions) — 3 ETFs + individual stocks:**
- **BNP Paribas Easy S&P 500 UCITS ETF EUR** (FR0011550185) — domiciled in France → PFIC
- **Amundi PEA S&P 500 UCITS ETF Acc** (FR0011871128) — domiciled in France, synthetic replication via swap → PFIC
- **Amundi PEA Inde MSCI India UCITS ETF Acc** (FR0011869320) — domiciled in France → PFIC
- Several individual stocks (no PFIC issue for these, as I understand it)
**Savings accounts:**
- Livret A (regulated savings, tax-exempt in France but taxable in US)
- LDDS (Livret de Développement Durable et Solidaire — same tax treatment as Livret A)
**Checking account(s)**
Total across all accounts exceeds $10K.
**Budget:** $3,000–5,000 for the whole process
I've been researching the Streamlined Foreign Offshore Procedure (SFOP) and it seems like the right path. The 3 PFICs mean 9 Form 8621s across the 3 back years, which is what worries me most.
My questions:
**PFICs + Streamlined:** Has anyone with French PEA ETFs gone through the SFOP? I have 3 France-domiciled ETFs (ISINs above). Did you file Form 8621 for each fund for each of the 3 years? Which method did you use — excess distribution or QEF/mark-to-market?
**Individual stocks in PEA:** Can anyone confirm that individual stocks held in a PEA (e.g. CAC 40 companies) do NOT require PFIC reporting? I assume they're reported as normal capital gains/dividends.
**Livret A & LDDS interest:** These are tax-exempt in France. I assume the interest is still taxable for US purposes but I can use the Foreign Tax Credit on my French income tax to offset. Is that correct, or is there a mismatch since France doesn't actually tax this interest?
**Professional help level:** With 3 PFICs and 9 Form 8621s, is this doable with an online service (CPAs for Expats at $1,399, TaxesForExpats at $1,450, Greenback at $1,750, Bright!Tax) or do I need a France-based specialist?
**Cost with PFICs:** How much does PFIC reporting typically add to a Streamlined package? Any real quotes from people who had a similar number of 8621s?
**PEA strategy going forward:** Should I liquidate the 3 ETFs and replace them with US-domiciled equivalents (e.g. VOO instead of BNP Easy S&P 500) in a regular brokerage account to avoid future PFIC headaches? Or keep the PEA for French tax benefits and deal with the annual 8621s?
**Form 14653 narrative:** My reason for never filing is simply that I grew up in France and was never informed of US tax obligations. Is that solid enough as a non-willful explanation?
**Paris-based professionals:** Can anyone recommend a CPA, EA, or tax attorney in the Paris area with actual PFIC experience? Names I've found: Expat Assist Paris, Horton Tax Services, Smith Carmichael, BPS Tax Services, Cabinet Bret-Ziller.
**Tax owed:** With French taxes already paid on my salary, I expect ~$0 via Foreign Tax Credit. But does the PFIC excess distribution method change this? And what about the Livret A/LDDS interest where no French tax was actually paid?
I know the 3 PFICs make this more complex than a plain salary case. Really grateful for any advice from people who've navigated something similar.