Accidental Americans in Brittany: when being born in the US still has consequences

According to a recent article in the Breton newspaper Le Télégramme, thousands of French citizens, including many people in Brittany, were born in the United States without ever living there long-term. These “Accidental Americans” may nevertheless face the consequences of their US citizenship, including FATCA requirements, requests for a US tax identification number, banking difficulties and US tax obligations.

Le Télégramme reports the case of a French woman born in the United States who has been dealing with the consequences of FATCA for years. Because she does not have a US tax identification number, she is concerned about difficulties with her bank and has encountered obstacles when trying to access certain financial products, including investments and life insurance.

Her experience illustrates the situation some Accidental Americans can find themselves in: being considered a US citizen because of their place of birth, despite never having actually lived in the United States.

Who are the Accidental Americans in Brittany?

“Accidental Americans” are people who hold US citizenship without necessarily considering themselves American. For some, their main connection to the United States is simply that they were born there.

In Brittany, this situation can partly be explained by the region’s particular history of emigration to the United States.

During the 19th and 20th centuries, many Bretons crossed the Atlantic to settle in the United States. Emigration was particularly significant around Gourin in Morbihan, a town known for its historic ties with America.

Some families later returned to France with children who had been born in the United States.

Decades later, that US birthplace can still have consequences. Under the US principle of birthright citizenship, a person born in the United States generally acquires US citizenship at birth.

They may therefore still be considered a US citizen even if they have lived in Brittany since childhood and have never worked or built a life in the United States.

Why can FATCA cause problems?

This situation has become particularly visible because of FATCA, the Foreign Account Tax Compliance Act.

FATCA is US legislation designed to combat the concealment of foreign financial assets by US taxpayers. Under the agreement between France and the United States, French financial institutions are required to identify certain customers considered US persons and report required information about their accounts.

A US place of birth can be an indication of US citizenship.

A French bank may therefore ask a customer to provide their US Taxpayer Identification Number (TIN), generally their Social Security Number (SSN).

Born in the US, but without a US tax identification number

Some people who have lived in Brittany for decades do not have a US tax identification number. They may have left the United States as children and had virtually no contact with US authorities since then.

A request from their bank can therefore lead them to discover, sometimes very late in life, that the United States still considers them US citizens.

Not having a TIN or SSN can complicate their relationship with their bank. Difficulties may also arise when opening an account or accessing certain financial products, investments or life insurance policies.

The issue can therefore extend well beyond simply providing a number to the bank.

Does an Accidental American have to file a US tax return?

US citizenship can also result in US tax obligations.

Unlike most countries, the United States bases tax obligations not only on residence but also on citizenship. A US citizen living in France may therefore be required to file a US tax return even if they live and pay taxes in France.

Depending on the individual situation, this can include an annual US income tax return as well as reporting requirements for certain financial accounts and assets held in France.

This does not automatically mean that an Accidental American will pay tax twice on the same income. The US-France tax treaty and various provisions within the US tax system can help prevent or reduce double taxation.

US filing and reporting obligations may nevertheless remain.

For someone who discovers after decades in France that they are still considered a US citizen, it is therefore important to distinguish between two questions: do I have to file in the United States, and do I actually have US tax to pay?

What if you have never filed a US tax return?

Discovering that you may have US tax obligations does not mean you should immediately file several years of tax returns without first assessing your situation.

The appropriate course of action depends on factors including your personal history, income, financial accounts, assets and whether you were previously aware of your US tax obligations.

In certain circumstances, procedures are available that allow US citizens living abroad to bring their US tax affairs into compliance.

It is therefore advisable to first establish which obligations actually apply to you before taking action with the IRS.

Can you renounce US citizenship?

For some Accidental Americans, another question eventually arises: can I renounce my US citizenship?

Yes. A US citizen can formally renounce their citizenship. Since 2026, the administrative fee for renunciation has been reduced from $2,350 to $450, significantly lowering the cost of the procedure.

Renunciation nevertheless remains an important and generally irreversible decision and should therefore be carefully prepared.

It is also essential to distinguish between the citizenship renunciation process and US tax obligations. Paying the $450 fee and obtaining a Certificate of Loss of Nationality (CLN) do not automatically eliminate any previous US tax obligations.

Before starting the process, it is therefore advisable to review your US tax position and determine which steps, if any, may need to be taken before or after renunciation.

What should you do if you are an Accidental American in Brittany?

If you were born in the United States but have lived in Brittany or elsewhere in France for many years, a FATCA request from your bank may be the first indication that your US citizenship requires attention.

Your situation depends on factors including your citizenship status, US tax filing history, income, accounts and investments in France, and any current connections with the United States.

Depending on your circumstances, different options may be available: determining your US tax obligations, applying for an SSN or TIN if necessary, bringing previous tax filings into compliance, or considering the implications of renouncing US citizenship.

Get Informed with Americans Overseas

We, the founders of Americans Overseas, were born in the Netherlands and received our American citizenship through our (American) mother.

When we first learned about the U.S.–Netherlands tax treaty around 2013, we felt disbelief (“this can’t be true”), anger (“how can they do this?”), fear (“will I get fined or have problems?”), and panic (“what should I do?”).

Unfortunately, it is true that there is a U.S. tax obligation for Dutch citizens who acquired American nationality by birth. There was no information from local authorities, the U.S. consulate referred us to the IRS, and the IRS itself was impenetrable.

That is why we started this initiative: to help others with reliable information, to prevent unnecessary panic, and to offer free, no‑obligation assistance. When needed, we can connect you with a network of affordable professionals (accountants) who can help you meet your U.S. tax obligations.

Contact us for more information

Source: Le Télégramme – “De plus en plus de cas de figure”: le cauchemar des Américains accidentels, dont des Bretons, s’achèvera-t-il un jour?