US to France - tax implications

Hi all,

I am a French citizen and US resident for tax purposes. I will be moving back to France in 2025 and I am starting to gather information about my tax obligations for that transition year. I am posting this here in case other people have been in the same situation and have wisdom to share.

I am somewhat aware of the rules for dual-status tax returns in the US and I am somewhat familiar with the US France tax treaty.

What is unclear to me is whether I will be considered a French resident for tax purposes for all of 2025 or only starting the day I move back.

This matters in part because the US France tax treaty has tie-breaker rules to determine tax residency when one meets the tax residency criteria of both countries at the same time. If I were to be considered a French resident for all of 2025 from France’s perspective, these tie-breaker rules would kick in and establish that I am a French resident for tax purposes, and therefore a US nonresident, which would have implications for how I file my US tax return (and more importantly where my US-sourced income is taxed and how).

According to this information page from a French government website, I will have to declare my worldwide income in France received on or after the day I move back, so I interpret this as saying that I will not be considered a French resident for the full year, which means I will be dual-status in the US (resident until I leave, nonresident after) and in France (nonresident until I move back, resident after).

Has anyone here been in this situation and how did it all work for you?

Thanks!