In a recent blog, Bankler Partners explore the complex tax considerations highlighted by reports that George Clooney has acquired French citizenship and may consider renouncing his U.S. citizenship.
As the firm outlines, for high-net-worth individuals, leaving the U.S. tax system is far from straightforward. U.S. citizens are taxed on their worldwide income regardless of residence, meaning that even those living abroad must continue to navigate U.S. tax obligations. While tax treaties—such as the U.S.–France agreement—can help mitigate double taxation through mechanisms like foreign tax credits and exclusions, dual citizenship can still involve significant compliance and planning challenges.
Bankler Partners note that renouncing U.S. citizenship is not necessarily a simpler solution. Under Section 877A of the Internal Revenue Code, certain individuals may be subject to an “exit tax,” which effectively treats all global assets as if they were sold before expatriation. For individuals with substantial wealth, this can result in a significant immediate tax liability.
The blog also highlights that broader considerations often influence such decisions. These include ongoing links to the U.S., business interests, lifestyle factors, and reputational considerations. In practice, individuals in comparable situations typically undertake extensive pre-expatriation planning to manage potential tax exposure.
In addition, the firm draws attention to the French tax landscape, including transitional provisions for new residents and the potential application of French wealth taxes and exit taxes over time. These factors may influence whether a long-term relocation strategy is viable
While the scale of Clooney’s situation is exceptional, Bankler Partners emphasise that similar principles apply more broadly. Citizenship, residency, and tax obligations are increasingly interconnected in a globalised world, and decisions around relocation or expatriation require careful, forward-looking planning.
Bankler Partners: IAPA Profile
Image Credit: Lake George Stock photos by Vecteezy
Date 01/06/2026
