This paper is intended to analyze the differences and similarities between social housing policy in the United States and in France, so as to give a perspective to countries around the world on options for housing lower-income families. In France, housing is considered a right and, therefore, an obligation of the government to provide for its citizenry. While the provision of housing in the United States does not hold the same legal or ethical status as it does in Europe, the country still has provided a number of policies to provide housing for those in need. The tools for subsidized housing in both countries are quite varied. Whereas they are piling up in France, they have substantially changed over time in the USA. In France, the main subsidy mechanism is now housing allowances. This tool was seen as equitable, and efficient, and, at least in theory, gave tenants more control over their living situations. France nonetheless still uses supply-side subsidies to stimulate affordable rental housing, providing traditional social housing providers with a mix of upfront and tax subsidies and attracting private investors with tax subsidies.

The development of subsidized rental housing estates really began in the USA after the Great Depression and in France after World War II, but has changed dramatically since that time, relying more heavily on tools that can be used by the private sector. This comparison will show that the relevant solution to housing problems in a given context should be based on the correct diagnosis of this problem and also be dependent upon the specific situation in that country, state or locality. This is the best way to create efficient, sustainable, affordable financing mechanisms for local, municipal and state governments. This paper will discuss the different methods by which the United States and France have addressed the challenges. For the U.S., we will highlight two programs: the low-income housing tax credit program, which uses the tax code as an incentive, and the capital fund financing program, which allows public housing authorities to securitize an ongoing stream of funds and use this to modernize properties. France introduced tax subsidies to the private sector at the same period, but in addition, not as a substitute, to public housing. After heavy taxes had deterred private investors, generous tax incentives brought them back towards rental housing. Few of these programs were affordable to moderate-income households. This resulted, in recent years, in an aftermath of the production of public housing units, requiring an increasing commitment from the municipalities.