US shares and RSUs: what changes when you move to France?

You received shares or Restricted Stock Units from a US employer before moving to France. Some vested abroad; others vested after your arrival. You may also have sold shares through a US brokerage account.

The French tax position cannot be established from the sale proceeds alone.

Start with the plan documents

“RSU” is a familiar label, but it does not establish which French tax rules apply.

The terms of the award, the relevant dates and any French provisions attached to the plan must be reviewed. A foreign award does not automatically qualify for the specific French tax regime for free shares.

This distinction can affect both the treatment of the employment benefit and the year in which it becomes taxable.

Separate the employment benefit from the subsequent sale

Receiving shares through employment and later selling them are distinct events.

The employment-related benefit and the subsequent increase or decrease in the shares’ value may require separate calculations. A US broker’s reported gain or cost basis should therefore be checked before being used for French reporting.

The figures must also be established in euros using the appropriate conversion method.

An international move adds another layer

Where the award relates to work performed in more than one country, the employment history over the relevant period may affect the allocation of taxing rights.

Your residence on the sale date is important, but it may not answer every question. The applicable tax treaty and any foreign tax already charged must also be considered.

Keep the underlying records

Award agreements, vesting statements, employer tax summaries, brokerage records and your international employment timeline are useful starting points.

Reviewing these documents before filing helps identify missing information and avoid inconsistent reporting.

NAS Avocat assists English-speaking clients with the French tax treatment and reporting of employee share awards, including situations involving an international move.