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Who are France’s ‘accidental Americans’ and why are French MPs talking about them?

'Accidental Americans' are the subject of a proposed amendment to France's new cost-of-living bill, but who are these people trapped in an Orwellian tax nightmare?

Who are France's 'accidental Americans' and why are French MPs talking about them?
'Accidental Americans' protest against current tax laws. Photo: AFP

These are French citizens who also have American citizenship – often without even knowing it. They have come together to fight against the ways they are harmed from American legislation reaching outside its borders, namely in regard to taxation and access to banking.

Most recently, ‘Accidental Americans’ have come back into the forefront after an amendment to the second purchasing power bill passed through France’s Assemblé Nationale. 

The amendment calls for the reciprocal application of the Fatca (explained below) between the United States of America and France and seeks to draw the Government’s attention to the situation of French citizens known as “accidental Americans.” 

While it is unlikely the amendment will have any day-to-day impacts on ‘Accidental Americans’ and Americans living in France, if passed by the Senate and put into law, it could put pressure on French banks. This might in turn encourage the French government to pay attention to the situation of ‘Accidental Americans’ and the safety of data transfers from French banks to the United States.

Ultimately, the amendment is a “strong sign” after “many years of efforts” according to Fabien Lehagre, the President of Accidental Americans. 

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Who are the ‘accidental Americans’?

There are thousands of ‘accidental Americans’ spread around France, all they have in common is the fact that they are entitled to American citizenship. Some of them had left America in the days after being born in an American hospital. Some of them didn’t even know they were technically American. Some of them don’t even speak English.

There are estimates that there may actually be as many as 40,000 ‘accidental Americans’ in France, thousands of whom still do not know that they technically have American citizenship, and up to 300,000 across Europe. While formally giving up US citizenship is an option, it can be long and costly.

What does the ‘accidental Americans’ Association (AAA) do?

AAA began in November 2014 when a Paris-based sales manager Fabien Lehagre received a letter from his bank asking him for his American tax identification number (TIN). Lehagre had been born in the United States in 1984, but he arrived in France at the age of just two with his French father. He has never lived in America since then. Having no idea that he was legally a US taxpayer, Lehagre first thought there had been a mistake. But he then discovered that he had acquired American citizenship at birth and consequently was supposed to declare all his revenues to the US Internal Revenue Service (IRS).

Lehagre then decided to fight the principle of Citizen Based Taxation (CBT), which applies only in the US and Eritrea. And, in August 2015, he set up the ‘accidental Americans Association’.

How did this situation arise?

In 2010, American President Barack Obama signed Fatca, or the Foreign Account Tax Compliance Act, into law.

This was a measure to force banks worldwide to scour client lists and report anyone who could be a US citizen, or face being barred from operating in the US. Fatca was passed in the aftermath of scandals involving Swiss banks helping wealthy Americans avoid taxes, but has ensnared millions of US citizens of modest means.

It was intended to target multinationals skimming their tax bills. But some individuals have become collateral damage as they were suddenly revealed to be technically American citizens living abroad. They only realised their involvement when the IRS started sending out bills for overdue taxes.

Applied in France since 2014, Fatca requires French banks to disclose to the US tax authorities personal data, assets exceeding $50,000 (approximately €40,000) and transactions of all their US clients. French banks are threatened with a hefty 30 per cent tax on all their American transfers if they do not give all this financial data.

This has a knock-on effect on US nationals who move to France, since many French banks are reluctant to open accounts for American clients because of the extra reporting requirements. 

What is France doing to help its citizens avoid double taxation?

The AAA has sought out political support for their campaign to end double taxation. French President Emmanuel Macron has been vocal in his support of the efforts of these ‘accidental Americans’ to loosen their ties to the United States. Macron even wrote about this situation to Richard Ferrand, who was the parliamentary leader of the president’s La République En Marche party.

“I am well aware of the preoccupations that you wished to inform me of,” Macron wrote. He added that France had sent a delegation to the U.S. in May to address the issue. “The dialogue continues, and believe me, I remain attentive to it,” Macron concluded in the letter, which was passed onto Lehagre. It is unclear, though, if Macron has followed through on his promise to raise the issue with US President Trump.

What is the latest?

The AAA mounted something of a sting operation by getting lots of its members to try to open new bank accounts online. They were shocked by the results, saying that the banks did not want them because they were technically also American citizens.

They then filed a discrimination lawsuit against several banks.

The group is also pressing a case before the European courts, based on the fact that Fatca is not compliant with European data laws.

It continues its political efforts, such as calling for the French government to take up the issue at a higher level. 

Member comments

  1. I feel sorry for the accidental Americans in Europe and elsewhere. The problem is not new and goes back to the Civil war when ‘The Revenue Act’ was passed by lawmakers. This meant that US persons outside the US became obligated to pay income taxes to the US Treasury. At the end of WW2 President Roosevelt realized that the British Empire was over and thus the reserve status of the GPB was over. During the Bretton Woods Conference and subsequent agreement the USD became the reserve currency. Most international transactions are in USD. This allows the US to run constant budgetary deficits as USD are recycled back into the US. Reaching out and legally stealing money from ‘accidental Americans’ increases demand for USD as the IRS receives tax payments in USD. The practice can be seen as an additional component in the US strategy for world domination.

    I applaud the French for standing up against the injustice of US strong arming. Unfortunately nothing will be done to help as the only voters that matter in the US are those with a powerful lobby representing their interests.

    I’m not an accidental American but the US taxation system makes my life as a small businessman quite different. These days I spend most of my time in the EU. That said I’m stuck in this awful system for the rest of my life.

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POLITICS

Revealed: France’s funniest politicians and their best ‘jokes’

Politicians' jokes are more usually met with a groan than a laugh, but France's annual prize for political humour has been awarded - here are the zingers judged the best in 2022.

Revealed: France's funniest politicians and their best 'jokes'

According to the jury on the Press club, Humour et Politique awards, the funniest politician in France is the Communist leader (and 2022 presidential candidate) Fabien Roussel.

His award-winning zinger is: “La station d’essence est le seul endroit en France où celui qui tient le pistolet est aussi celui qui se fait braquer.”

It translates as ‘the petrol station is the only place where the one holding the gun is also the one who is robbed’ – a joke that works much better in French where ‘pistolet’ means both a pistol and the petrol pump. 

On a side note for British readers – Roussel also looks quite a lot like left-wing UK comedian Stewart Lee, so maybe he has funny genes.

Second prize went to ex-president Nicolas Sarkozy with his withering assessment of Valérie Pécresse, the candidate for his old party in the 2022 presidential election, who did extremely badly.

“Ce n’est pas parce que tu achètes de la peinture, une toile et des pinceaux que tu deviens Picasso. Valérie Pécresse, elle a pris mes idées, mon programme et elle a fait 4.8 pourcent”

“It’s not because one buys paints, canvas and brushes that you become Picasso. Valérie Pécresse, she took my ideas, my manifesto and she got 4.8 percent of the vote.”

While these two were jokes – in the loosest sense of the word – the prize can also be awarded to politicians who make people laugh inadvertently, such as last year’s winner Marlène Schiappa who, when announcing plans to ban polygamy, felt the need to tell the French, “On ne va pas s’interdire les plans à trois” – we’re not going to outlaw threesomes.

Here’s the full list of finalists for the funniest political joke of 2022 – somehow we don’t think you’re at risk of split sides with any of these.

Ex-Prime minister Edouard Philippe talking about hard-left leader Jean-Luc Mélenchon: “Il faut une certaine audace pour que quelqu’un qui a été battu à une élection où il était candidat puisse penser qu’il sera élu à une élection où il n’est pas candidat!”

“It takes a certain audacity for someone who was defeated in an election where he was a candidate to think that he will be elected in an election where he is not a candidate!”

Ex-Assemblée nationale president Richard Ferrand: “Elisabeth Borne est formidable mais personne ne le sait.”

“Elisabeth Borne is great but no-one knows it.”

Ex-Macronist MP Thierry Solère: “Mon anatomie fait que si j’ai le cul entre deux chaises, je suis parfaitement assis.”

“My anatomy means that if I have my ass between two chairs, I am perfectly seated.”

Some information that might be useful for this one – the French phrase avoir le cul entre deux chaises (to have your ass between two chairs) is the equivalent of the English ‘falling between two stools’ – ie a person who cannot make up their mind what or who to support. Further information; Solère is a largish bloke.

Hard-left MP Eric Coquerel: “S’imaginer qu’on va remplacer Jean-Luc Mélenchon comme ça, c’est une vue de l’esprit. C’est comme se poser la question de qui va remplacer Jaurès.”

“To imagine that we will replace [party leader] Jean-Luc Mélenchon like that, is purely theoretical. It is like asking the question of who will replace Jaurès.”

Jean Jaurès is a revered figure on the French left, but not currently very active in politics, since he was assassinated in 1914.

Rachida Dati to Paris mayor Anne Hidalgo: “Votre présence au Conseil de Paris est aussi anecdotique que votre score à la présidentielle.”

“Your presence at the Council of Paris is as anecdotal as your score in the presidential election.”

There’s no doubt that Hidalgo did humiliatingly badly in the presidential election with a score of 1.75 percent. Daiti didn’t stand in the presidential elections but she did put herself forward to be mayor of Paris in 2020 and was convincingly beaten by . . . Anne Hidalgo.

So that’s the ‘jokes’, but there were also some entries for inadvertently funny moments.

Paris mayor Anne Hidalgo: “Tous les matins, je me lève en me disant que tout le monde m’aime.”

“Every morning, I wake up and tell myself that everyone loves me.”

But the undisputed queen of this genre is the green MP Sandrine Rousseau, whose ideas and policy announcements seem to have provoked a great deal of mirth.

Je voudrais qu’il y ait une possibilité de délit de non-partage des tâches domestiques – I would like there to be the possibility of a crime of not equally sharing domestic tasks

Les SDF meurent plus de chaleur l’été que l’hiver – The homeless die from heat more in the summer than the winter

Il faut changer aussi de mentalité pour que manger une entrecôte cuite sur un barbecue ne soit plus un symbole de virilité – We must also change our mentality so that eating a steak cooked on a barbecue is no longer a symbol of virility.

If you prefer your humour a little more scientific, Phd researcher Théo Delemazure has done a study of which politicians and political parties are funniest when speaking in parliament.

He analysed how often speeches raise a smile or a laugh (which presumably includes sarcastic laughter) and concluded that the party that gets the most laughs is the hard-left La France Insoumise.

They are also the party that speaks most often, however, when he calculated the laughter rate per time spent speaking, the prize went to the centre-right Les Républicains.

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