Foreign accounts: reporting and regularisation in France
A French tax resident reports every year the bank accounts, digital asset accounts and life insurance contracts held outside France, and the income they produce. An omission is penalised per account and per year, and extends the period during which the tax authorities may reassess.
The firm lists the accounts and contracts concerned, reconstructs the taxable income and prepares the returns, including to regularise past years.
How are foreign accounts reported or regularised?
- Listing the accounts, contracts and digital asset portfolios to be reported.
- Reconstructing foreign-source income and gains, and treaty tax credits.
- Forms 3916 and 3916 bis, and reporting the income on the main return.
- Regularising the years still open and quantifying penalties and late-payment interest.
- Dealing with the tax authorities in the event of an information request or audit.
What are the figures and thresholds for 2026?
| Item | Value | Reference |
|---|---|---|
| Penalty per undeclared account | €1,500 | Art. 1736 IV CGI |
| Penalty, State without an assistance agreement | €10,000 | Art. 1736 IV CGI |
| Tax authorities’ assessment period | Up to 10 years | Art. L. 169 LPF |
In which cases has the question arisen?
Regularising previously undeclared foreign accounts
Voluntary disclosure of omitted foreign securities accounts: reconstructing the flows, years to correct, exposure to penalties and lasting compliance.
Regularising Crypto-Asset Wallets Held Abroad
Voluntary regularisation of undeclared crypto-asset wallets and of the corresponding capital gains: characterising the accounts, reconstructing the portfolio, exposure to penalties and the request for remission.
Advising a US citizen settling in France
A US person settling in France on a long-term basis: France–US tax coordination (FBAR, FATCA, PFIC, CFC), review of investments, trusts, real estate and succession.
Returning to live and work in France after several years abroad
Advising a senior executive returning to France: date of tax residence, inbound (impatriate) regime, treatment of foreign income and assets, and IFI for new residents.
Supporting a financial institution with its tax and reporting obligations
A financial institution serving French tax resident clients: tax treatment of products, return no. 2777, production of the IFU statements and tax management of PEAs.
Frequently asked questions
Which accounts held abroad must be reported?
Under article 1649 A of the French Tax Code, accounts opened, held, used or closed abroad, on form no. 3916-3916 bis, including digital asset accounts and life insurance contracts taken out outside France.
What is the penalty for an undeclared account?
A €1,500 penalty per account and per year (€750 for a digital asset account with a balance of no more than €50,000), raised to €10,000 where the account is in a State without an administrative assistance agreement with France (article 1736 of the French Tax Code). The assessment period may be extended to ten years.
Can undeclared accounts be regularised?
Yes. Returns for the years still open can be filed voluntarily, with the corresponding income; penalties and late-payment interest remain due.
Answers current as at 9 October 2026
Publications and award
2026 OCCUR Prize, Interprofessional CollaborationLa Rencontre OCCUR Paris
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ArticlesThe firm’s articles on the National Bar Council’s platform
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Discussing your situation
A first meeting identifies the questions raised by your situation and the work they call for.