France vs United States

Companies in France (commonly a SARL or SAS) are registered through the single online business-formalities portal, which files with the national business register (RNE) and issues a SIREN number. Steps include drafting statutes, depositing capital and publishing a legal notice.

There is no federal company registry in the U.S. — you form a company (usually an LLC or C-corporation) at the state level, most often in your home state or Delaware. Formation is fast and online in most states; you then obtain a federal EIN from the IRS for tax and banking.

France's banking includes large retail banks and growing online banks. Opening an account usually needs ID, proof of address and a residence status; a French account is often required for rent and utilities. The Banque de France oversees the system.

To open a U.S. business bank account you generally need an EIN, your formation documents, ownership / beneficial-owner information, and ID for the signers. Banks run KYC (identity) and anti-money-laundering checks. Requirements vary by bank, business structure and owner residency. Non-residents can often open an account, but some banks require a U.S. address, a U.S. phone number, or an in-person visit. Personal accounts follow similar identity checks but use personal ID and a Social Security Number (SSN) or ITIN.

France courts foreign investment through Business France and the 'Choose France' initiative, with free movement of capital. Investments in sensitive sectors need prior authorization under the foreign-investment control regime (run by the Treasury); incentives include the research tax credit (CIR) and regional aid.

The U.S. welcomes foreign direct investment — starting a company, expanding, acquiring a business, or building manufacturing/R&D/logistics operations. There is no single federal approval office: SelectUSA promotes investment at the federal level, most incentives are offered by state and local agencies, and some deals are reviewed by CFIUS for national security. Public-company filings are free on SEC EDGAR, and FDI statistics are published by the BEA.

France taxes personal income progressively with pay-as-you-earn withholding, adds social levies, and applies VAT (TVA) to most goods and services; corporate tax applies to companies. Tax residents are taxed on worldwide income.

The U.S. taxes federal income (IRS) plus state and often local taxes; rates vary by state and some have no income tax. U.S. citizens and residents are taxed on worldwide income — the U.S. is unusual in taxing citizens who live abroad. Businesses file federal and state returns.

Non-EU nationals generally need a work authorisation and a long-stay visa or residence permit to work in France; the 'Talent Passport' covers skilled workers, founders and researchers. EU/EEA citizens work freely. The process involves the employer, labour authorities and French consulates.

Most people work in the U.S. on an employer-sponsored nonimmigrant visa such as the H-1B (specialty occupation, capped and lottery-based), L-1 (intra-company transfer) or O-1 (extraordinary ability). Almost all routes require a U.S. employer to petition for you with USCIS; there is no general 'work visa' you can apply for on your own.

Non-EU students staying longer than three months need a long-stay study visa, usually the VLS-TS "étudiant". Its defining feature: once you validate it online within three months of arrival, it doubles as your residence permit — no separate permit application. In many countries the process runs through Campus France's "Études en France" procedure before the consular step. It allows part-time work and Schengen travel.

Full-time study in the United States generally needs an F-1 student visa (M-1 for vocational study). An SEVP-certified school admits you and issues a Form I-20; you then pay the SEVIS I-901 fee, complete the DS-160 and attend a visa interview at a US embassy or consulate. You must show funds for tuition and living costs and ties to your home country.

France is in the Schengen Area, so short tourist or business visits follow Schengen rules: up to 90 days within any 180-day period across the whole area. Visa-exempt nationals can visit without a visa; everyone else applies for a short-stay (type C) Schengen visa through the official France-Visas portal. A new ETIAS authorisation is being introduced for visa-exempt travellers — check the current requirement.

Short visits to the United States use the B-1/B-2 visitor visa, unless you qualify for the Visa Waiver Program — nationals of participating countries travel for up to 90 days with an approved ESTA instead. B-visa applicants complete Form DS-160 and attend an interview at a US embassy or consulate. Visitor status never permits employment.

France's long-term residence is the carte de résident, typically a 10-year renewable card available after several years of legal residence (or immediately for some family of French citizens). The multi-year Talent Passport is a common step toward it.

U.S. permanent residence (a green card) comes through family, employment, investment (EB-5), the diversity lottery or humanitarian routes. Employment green cards (EB-1/2/3) usually require an employer and labor certification, and priority-date backlogs can be long.

French citizenship by naturalization generally requires five years' residence (reduced in some cases), integration, French language ability and stable resources. France allows dual citizenship, and marriage to a French citizen is a separate route.

U.S. citizenship by naturalization generally requires five years as a green-card holder (three if married to a U.S. citizen), continuous residence, good moral character, and passing English and civics tests. Those born in the U.S. are citizens by birth.

French employment is highly regulated by the Code du travail: a 35-hour legal working week, the SMIC minimum wage, five weeks' paid leave, and structured dismissal rules. Most jobs are permanent (CDI); employee representatives (CSE) and collective agreements apply, and disputes go to the labour court (conseil de prud'hommes).

US employment is generally 'at-will' — either side can end it — but federal law (the FLSA via the Department of Labor) sets minimum wage and overtime, and the EEOC enforces anti-discrimination rules. There is no federal statutory paid annual leave; states add their own protections, so your state matters.

French trade with non-EU countries goes through French customs (la Douane) with an EU EORI number. You classify goods in TARIC to find duty, and import VAT (20%) is now self-assessed on your VAT return. Declarations are electronic via DELTA; intra-EU flows need statistical (EMEBI/DEB) reporting and dual-use exports need a licence.

US importers and exporters clear goods through US Customs and Border Protection (CBP). You file entries under an importer number, classify goods by HTS code to find the duty rate, meet any partner-agency rules (FDA, USDA…), and pay duties. Exports follow the Export Administration Regulations; binding tariff rulings and disputes go through CBP.

French trademarks are registered with the National Institute of Industrial Property (INPI). You search the register, file an application classifying goods/services under Nice, and it publishes in the BOPI for a two-month opposition period before registration. A French trademark lasts 10 years and is renewable; an EU-wide alternative is the EU trademark via EUIPO.

US trademarks are registered with the US Patent and Trademark Office (USPTO). You search the register for conflicts, file an application specifying goods/services classes, and respond to examination before it publishes for opposition and registers. Registration lasts 10 years and is renewable; patents go through the USPTO and copyright through the Copyright Office.

France Travail is the public employment service and official job board — it was formerly Pôle emploi, so guidance still using the old name is dated. Non-EU workers generally need a work authorisation tied to a residence permit, such as salarié or passeport talent, which means the permit and the job are linked rather than separate matters. Certain shortage occupations, the métiers en tension, can have streamlined hiring, and Service-Public sets out the rules.

There is no single national job board for the US private sector — hiring is spread across company sites and commercial boards, so anyone looking for one official place to search will not find it. What does exist officially is split by sector: CareerOneStop, run by the Department of Labor, is the hub for job search, training and career tools, while USAJOBS covers federal-government roles. Foreign nationals generally need work authorisation in place before taking up a job, not after finding one.

France has a single national minimum wage, the SMIC, which applies across the country. Its distinguishing feature is the revaluation rule: it is revalued at least once a year and can rise mid-year if inflation triggers it — so unlike floors that move on a fixed annual date, a French figure can go out of date between scheduled updates. INSEE is authoritative for SMIC and average-wage statistics, while Service-Public explains the rules. Pay is quoted brut, with social contributions and income tax reducing net.

US pay is largely market-set, with the federal minimum wage as the legal floor — and that floor has been USD 7.25/hour since 2009, so in much of the country it is no longer the operative number. Many states and cities set higher minimums, and where they do, the higher rate applies. For earnings by occupation and area, use the Bureau of Labor Statistics' OEWS rather than crowd-sourced salary sites. The Department of Labor's Wage and Hour Division enforces minimum wage and overtime under the FLSA.

France's flagship scholarship for international students is the Eiffel Excellence Scholarship (France Excellence Eiffel), funded by the Foreign Ministry for master's and PhD, alongside university and regional awards. Campus France is the official portal to explore funding and apply to study in France. Apply by each scheme's deadline, which is often well before the course starts.

There is no single US government scholarship for all international students — funding is mostly institutional (university assistantships, fellowships and merit aid) plus flagship programs like the Fulbright Foreign Student Program. Start with EducationUSA advising and each university's financial-aid office, and apply early because deadlines are often a year ahead.

To study in France, students from many countries apply through the 'Études en France' procedure (via Campus France), then, once admitted, apply for a VLS-TS long-stay student visa, which you validate online within three months of arrival. Public university fees are low, though some are higher for non-EU students. Explore options on Campus France and apply by the deadline.

To study in the US you apply directly to each university, and once accepted the school issues a Form I-20 that lets you get an F-1 student visa (pay the SEVIS fee, complete the DS-160 and attend a consular interview). Use EducationUSA advising to shortlist schools, and apply about a year ahead because admission and funding deadlines are early.

France places no restriction on foreigners buying property. Renting is tenant-protective (the 1989 law): the deposit (dépôt de garantie) is capped at one month's rent for unfurnished homes (two for furnished), and agency fees are regulated. Buying goes through a notaire, is registered at the land registry (publicité foncière), and carries 'frais de notaire' of roughly 7–8% (mostly transfer duties).

The United States places no restriction on foreigners renting or buying a home. Renting usually means a credit/income check and a security deposit (commonly one to two months' rent, capped by many states). Buyers use a realtor and a title/escrow company; non-resident buyers can get a mortgage but typically need a larger down payment. Annual property tax is set locally.

France's Assurance Maladie covers anyone working or residing in France on a stable, regular basis through the Protection Universelle Maladie (PUMa). The model is reimbursement rather than free-at-point-of-use: the scheme repays a large share of costs and most people take a complementary "mutuelle" to cover the remainder. You manage cover, reimbursements and your carte Vitale through an Ameli account.

The US has no universal public healthcare. Most people are covered through an employer plan or buy coverage on the ACA Marketplace at HealthCare.gov, with Medicare for those 65+ and Medicaid for low-income residents under state-varying rules. Foreign nationals usually rely on employer or private insurance; lawfully-present immigrants can buy Marketplace plans but typically wait five years for Medicaid or Medicare. Care is very costly without coverage.

France's Sécurité sociale provides social insurance covering health, family, pensions and work accidents, with contributions collected largely through URSSAF. The detail that catches renters out is that France has two compulsory private insurances, not one: motor third-party liability, and home insurance for tenants. A complementary health mutuelle is widely held to top up Assurance Maladie, and insurers are supervised by the ACPR, part of the Banque de France.

US insurance has two layers that answer to different authorities. Federal social insurance — Social Security and Medicare — is funded by FICA payroll taxes and administered by the Social Security Administration. Almost everything else you buy (auto, home, life) is regulated by your state, not federally. Auto liability insurance is mandatory in almost every state, and to check an insurer is licensed you go to your state insurance department, whose directory is on the NAIC site.