thank you for your information.
Until you are present in the U.S. for 183 days, you will not be taxed as U.S. Citizens. However, after 183, days, by tax treaty between the U.S. and the UK (including ireland), and France, after 183 days you are taxed as U.S. citizens.
this means that your world wide income is reported to the U.S., based on your status in the U.S. at the end of the tax year, irrespective of when the actual sale of the property occurred.
By tax treaty, inlcuding the tax treaty between the UK and France, and thorughout the EU, France iwll have first claim to any taxes derived from capital gains.
Followed by the U.S. and then the UK.
However it flows like this:
Even though you will have to report the capital gains in each country by individual country rules, each country, because of the tax treaties must give you a tax credit for taxes paid to another jurisdiction.
So the U.S. will give you credit for taxes paid to France, and the UK will give you credit for taxes paid to France and the U.S. on your world wide income.
Because of this venue and the complicity of a three country tax situation, I am not going to be able to give you anyting other than what we call in the U.S., a Ball Park Figure for what your capital gains will be.
In my corporate experience, the company that has brought you here on an L-1 Visa should be providing free tax consulting for you, and the company retained by your company, (PWC, Earnst & Young, etc) would be able to give you a more accurate prediction. If your company is not providing these services to you, then I recommend you see your supervisor and HR manager about getting this service.
In the mean time, i will provide a basic capital gains picture for you, which as i said will only be ball park.
The figures will be coming in the next response.
Can you tell me this?
1. How much did you pay for the property when you bought it?
2. Is it privately held or did you form or join an organziatin to buy it?
3. Was it used as a rental?
4. Where in France is it located?
5. What is its Fair Market Value now? (what do you expect to sell it for?)
6. Do you have an approximate figure for your improvements and major repairs?