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French mortgages for Americans

US citizens can borrow in France, but FATCA narrows the list of willing banks. What to expect and how to prepare a file that gets read.

Paris rooftops and the Eiffel Tower at sunset
The short answer

Americans can buy and borrow in France on the same legal terms as anyone else. The obstacle is FATCA: every account and loan held by a US person must be reported to the IRS, and some French banks decline US clients rather than carry that work. Lenders that do accept US files typically finance 50–70% of the price, so plan for a deposit of 30–50% plus 7–8.5% purchase costs on an existing home.

Why FATCA narrows the field

The Foreign Account Tax Compliance Act requires banks outside the United States to identify clients who are US persons and report their accounts to the IRS each year. A French loan comes with a French current account, so it falls inside that reporting. Large French banking groups are registered for FATCA, but registration does not mean every regional bank or branch has a credit policy that accepts US borrowers. Many decline them quietly, after weeks of paperwork.

The rule applies to US citizens wherever they live and to green card holders and US tax residents. An American living in London or Dubai meets the same filter as one living in Boston.

Deposit and loan size

PriceAt 50% financingAt 70% financing
€600,000Loan €300,000Loan €420,000
€1,200,000Loan €600,000Loan €840,000
€2,500,000Loan €1,250,000Loan €1,750,000

Purchase costs on an existing property come from your own funds on top. Some lenders set minimum loan sizes of €250,000 or more for US borrowers.

Brokers report that banks are most comfortable with US files in the markets they know resell well: Paris, the Alps and the Côte d'Azur. Above roughly €1 million, private banks become an option, usually in exchange for assets placed with them, and can offer interest-only or variable structures.

Presenting US income to a French bank

French banks do not use FICO scores. A strong credit history in the US carries little weight; documents carry it all.

  • Passport and proof of address
  • W-2 forms and recent pay stubs, or two to three years of business returns if self-employed
  • Your last two Form 1040 federal returns, with schedules
  • Three to six months of statements for checking, savings and brokerage accounts
  • Statements for your US mortgage and other loans, which count against the 35% ceiling
  • Proof of the deposit's origin for the bank's and the notaire's anti-money-laundering checks

Expect the bank to convert your dollar income cautiously. Bonus, carried interest and RSU income often count only in part, or only with a long track record.

Own names, SCI or something else

Americans are often told to buy through a French SCI. The company can help with French inheritance rules, but its US tax treatment needs care: depending on elections made, the IRS may see it as a partnership or as a foreign corporation, with very different reporting. Settle this with a US tax adviser and a French notaire before the compromis, because the bank lends to whoever is named as the buyer. Our SCI guide covers the financing side.

US reporting once you own

  • FBAR. If your foreign accounts together exceed $10,000 at any point in the year, you file FinCEN Form 114. Your French current account counts.
  • Form 8938 may also apply above higher thresholds.
  • Rental income is taxed in France and reported in the US, with credit for French tax under the France–US treaty.
  • Exchange gains on the mortgage. Repaying a euro loan can create a currency gain or loss for US tax purposes when the dollar moves. Ask your US adviser before you choose between a mortgage and cash.

French-side returns and fiscal representation when you sell are handled by French Tax Online.

Dollars to euros

The dollar can move several percent against the euro between your offer and completion. A forward contract fixes the rate for the deposit transfer in advance, and a standing monthly transfer converts repayments at a set margin. Our currency partner arranges both, and the French account receiving the funds is the one the lending bank opens for you.

Questions Americans ask

Can a US citizen get a mortgage in France?

Yes. Fewer banks accept US persons because of FATCA reporting, so the search takes longer and deposits are larger, typically 30–50% of the price. A broker who places US files regularly knows which lenders are taking them.

Can I use my US home equity instead?

You can, and some buyers do. It leaves a dollar loan against a euro asset and removes the French bank's checks, which some see as an advantage and others as a missed safeguard. Compare the all-in cost of both.

Do I need to fly to France to sign?

Not necessarily. A notaire can prepare a power of attorney so the deed is signed for you. Many buyers attend the compromis or the completion, but rarely both.

Next step

Use the eligibility check and answer yes to the US person question. We will introduce you to a broker who works with lenders that accept US files.