US-France Taxes for American Retirees: The Complete Guide

Reviewed for accuracy by Benjamin Pik, US Certified Public Accountant and Expert-Comptable & Commissaire aux Comptes from Expand CPA, a practice specializing in US-France cross-border taxation.

Moving to France does not mean France automatically starts taxing your Social Security, 401(k), IRA, and other US retirement income at French rates.

For American retirees, the US-France tax treaty is unusually important. In many common situations, US Social Security and qualifying US retirement-plan distributions remain taxable in the United States rather than being taxed again by France.

But that does not mean you stop dealing with either tax system. US citizens generally continue filing US federal tax returns after moving abroad, while French tax residents generally file in France and report income from both countries. The treaty can produce favorable results for retirees, but filing in two countries still adds complexity.

This guide covers the common case of a US citizen who moves to France and becomes a French tax resident. Dual nationals, green-card holders, trusts, business owners, mixed-nationality couples, and people splitting their lives between countries can face different rules.

In this guide

• US-France retirement taxes at a glance
• The two tax systems you'll live under
• When does France consider you a tax resident?
• How the French tax system works
• Your first tax year in France
• What the US-France tax treaty does
• How different types of retirement income are taxed
• The French wealth tax (IFI)
• French social charges (CSG/CRDS)
• The PUMa health contribution (the "taxe PUMa")
• Inheritance and estate planning
• French financial structures US citizens should review carefully
• What you still owe the United States
• Your French filing obligations
• Your former US state may still matter
• What to review before you move
• Who needs specialist advice?
• Who can actually do your taxes?
• So how much will you actually pay?
• How Aelos handles taxes after you move

US-France retirement taxes at a glance

This table is deliberately simplified. The treaty mechanism and French reporting treatment differ by income category.

The two tax systems you'll live under

Once you retire to France, two tax systems apply to you at the same time.

The United States taxes its citizens on worldwide income, regardless of where they live. You generally keep filing a US federal return every year for as long as you hold US citizenship, no matter how long you have been gone.

France generally taxes its tax residents on worldwide income, subject to international tax treaties. So once you become a French tax resident, you will normally have French filing obligations as well.

There is a tax treaty between France and the US that determines which country gets to tax particular categories of income and how double taxation is relieved. That distinction matters: reporting income in France does not necessarily mean paying French tax on it.

When does France consider you a tax resident?

One of the most common misconceptions is that you only become a French tax resident after spending 183 days in France. French domestic law looks more broadly at your circumstances.

You can be considered domiciled in France for tax purposes if:

• your foyer, or habitual family home, is in France, or, if you do not have a foyer, your principal place of stay is there;
• your principal professional activity is in France; or
• France is the center of your economic interests.

For a retired couple moving together to establish their home in France, the foyer test can matter well before they have accumulated 183 days in the country. The 183-day count matters in some situations, but it is not a rule that lets you spend 182 days in France without becoming tax resident.

If both France and the United States consider you resident under their domestic rules, the treaty contains tie-breaker provisions that look at factors such as your permanent home, center of vital interests, habitual abode, and nationality. For someone genuinely moving to France to make it their home, tax residency should be reviewed around the actual date of the move, not simply at day 183.

How the French tax system works

A few basics, since you'll be filing inside it.

Income tax is administered by the Direction Générale des Finances Publiques (DGFiP), and returns are filed online at impots.gouv.fr, where every resident has a personal account. If you use a professional, they prepare the return and either file it under a mandate or hand it back for you to submit; either way, the account and the responsibility for what's filed stay with you.

Personal income tax (Impôt sur le Revenu) is progressive, running from 0% to 45% across five bands that are indexed each year. These brackets apply only to income France actually taxes; as the sections below explain, the treaty changes the treatment of many common sources of US retirement income.

France taxes the household (the foyer fiscal), not the individual. Married couples and civil partners bound by a PACS (pacte civil de solidarité, France's registered partnership) file jointly by default, and the household's income is divided across "parts" (the quotient familial) before the brackets apply, which often helps couples.

Since 2019, France collects income tax through the year (prélèvement à la source). Where there is no French payer to withhold from, such as your US pensions, France takes monthly or quarterly installments by direct debit based on your last return, with the balance reconciled when you file your annual return. This only changes the timing of any French tax, never the amount, so where the treaty leaves France little to tax, there is little to collect.

The annual return (déclaration de revenus) is filed in spring for the prior year's income, with online deadlines falling roughly between late May and early June depending on your département.

French-source dividends, interest, and gains are generally taxed at a flat rate (the prélèvement forfaitaire unique, 31.4% in 2026), or the progressive scale if it is lower. For US retirees, the treaty relieves US-source investment income in the first place, so this flat rate mainly reaches genuinely French-source investment income.

Your first tax year in France

If you become a French tax resident partway through the year, your first French tax return will be different from later ones. Your reporting obligations can differ for the periods before and after the move, and French-source income received before you became resident may need separate treatment.

Your first French income-tax return is generally filed in the spring following the year of your move. So if you move to France in October 2026, your first French income-tax filing would generally take place in 2027.

This is one reason to determine your likely French tax-residence date before making large transactions around the move. Selling investments, selling your US home, making a large retirement-account withdrawal, or completing a Roth conversion shortly before versus shortly after becoming French resident can produce different reporting and tax consequences.

What the US-France tax treaty does

The income-tax treaty between France and the United States dates from 1994 and has been amended by later protocols. Its job is not to make Americans in France tax-free. It assigns each category of income to one country or the other, or splits the taxing rights and provides a credit so the same euro isn't taxed twice. Inheritance and gifts are covered by a separate US-France treaty, discussed below.

For retirees, the articles that matter most are Article 18 (pensions and Social Security), Article 24 (relief from double taxation, which covers most US investment income), and Article 29 (the saving clause, which normally lets the US tax its own citizens as if the treaty didn't exist).

The treaty and its later protocol specifically recognize many common US retirement arrangements, including 401(a) plans, IRAs, and 403(a) and 403(b) plans. The US Treasury's technical explanation also identifies Roth IRAs as a type of individual retirement plan for these purposes.

How different types of retirement income are taxed

Even when France does not tax a particular source of income, you may still need to report it on your French return. In some cases, that income is also taken into account when calculating the effective rate (taux effectif) applied to other income.

Will France tax my US Social Security?

France does not tax it. Under Article 18 of the treaty, US Social Security paid to a French resident is taxable only in the United States. You still list it on your French return so France can work out your effective rate, but France charges no tax on it. Because Article 18 is carved out of the saving clause, this protection survives even though the US can normally tax its citizens as if the treaty didn't exist.

On the US side, your Social Security is taxed as it would be if you'd never left: depending on your total income, up to 85% of your benefits can be subject to US federal income tax. Moving to France doesn't raise that or stack a French tax on top.

How are my pension, IRA, 401(k), and annuity distributions taxed?

Under Article 18, as amended by the 2004 Protocol, qualifying pension and retirement-arrangement distributions are taxable only in the source country. For a US citizen, that means US employer plans, private pensions, 401(k)s, 403(b)s, and IRAs are taxable only in the United States, at US rates. The Treasury's technical explanation describes this as exclusive source-country taxation and specifically recognizes individual retirement accounts, so IRAs are covered on the same footing as employer plans rather than through a separate analysis.

You still report the distributions on your French return, where they count toward your effective rate, but France does not tax them.

One distinction is worth keeping in mind: not all retirement income falls under identical treaty provisions. Government pensions, private pensions, Social Security, and other arrangements can be treated differently, so if your retirement income comes from an unusual plan, confirm its classification rather than assuming the word "pension" settles the question.

Will France tax my US dividends, interest, and other investment income?

For a US citizen resident in France, US-source dividends and interest are not taxed by France. Under Article 24, France grants a tax credit equal to the French tax that would otherwise be due on this US-source income. Because the credit equals the French tax, it cancels the income tax and the CSG and CRDS social charges alike, so the income is taxed only by the US. Article 24 contains relief that is specific to US citizens resident in France, so this is not the ordinary result for every French resident who receives US dividends. (One separate French health contribution can still reach this income; it has its own section below.)

For the relief to apply, your French return has to include a specific declaration, the mention expresse, claiming it. You report the income in France; it simply has to be reported in the right way so the appropriate credit is applied.

How are my capital gains taxed if I sell US investments after moving?

For a US citizen resident in France, gains on the sale of US securities are generally not taxed by France, the same way dividends aren't. When you sell US-source securities (stocks, ETFs, funds), the Article 24 credit equals the French tax, so France collects nothing, and the same point about claiming it correctly applies.

This changes for income that isn't a clean US-source securities gain. Employer equity such as RSUs is treated differently, because part of that gain is really compensation, and part of it can relate to time spent in a particular country. Gains on non-US-source assets fall outside this relief and can be taxed in France at the flat prélèvement forfaitaire unique (31.4% in 2026). If you expect a large gain around the time of your move, review it before the sale rather than when you file the following year.

How are Roth IRAs treated? Do Roth withdrawals stay tax-free?

Qualified Roth distributions are tax-free under US law, and they are not taxed in France either. France has no domestic Roth equivalent, which once made the treatment look uncertain, but the established position is that a qualified Roth withdrawal is reported on your French return and not taxed. The US Treasury's technical explanation of the treaty protocol recognizes Roth IRAs under Internal Revenue Code Section 408A as a type of individual retirement plan eligible for the treaty framework, which is firmer support than the common claim that France simply "doesn't recognize Roths."

A Roth conversion is a separate question. A conversion can create taxable income in the United States, and its timing relative to your French tax residence should be modeled before you execute it.

Can I keep my US brokerage and retirement accounts?

Many Americans keep their US brokerage and retirement accounts after moving to France, and what you hold inside them matters on both sides.

On the US side, moving into French or European investment funds can create significant US tax and reporting issues: under the US PFIC rules, most non-US mutual funds and ETFs are taxed punitively for US citizens. On the French side, the treaty relief that keeps your investment gains out of French tax depends on those gains being US-source, so holding US-domiciled funds keeps your gains outside French tax while avoiding the US PFIC issues associated with many non-US funds.

One practical point: some US brokerages restrict or close accounts once you have a non-US address. Confirm your broker's policy before you move, and if needed choose one that serves Americans abroad.

What about my US rental property?

Rental income from US property is taxable in the US, and France relieves it through the effective-rate mechanism. You still report it on your French return, where it counts toward your effective rate.

The French wealth tax (IFI)

France has a wealth tax, but since 2018 it applies to real-estate assets and certain indirect real-estate holdings, rather than to your financial wealth generally. It is called the Impôt sur la Fortune Immobilière (IFI), and it applies when your household's net taxable real estate is worth more than €1.3 million on January 1. The word net matters here: outstanding mortgage debt on a property is deducted, so only your net equity counts toward the threshold. French rules restrict which debts are deductible, though, so not every loan reduces the base. It is an annual tax on a progressive scale that tops out at 1.5%.

Two points matter for retirees. It reaches real estate, including the real-estate value held indirectly through shares or interests in companies, but not your IRAs, brokerage accounts, and cash, so many retirees never reach the threshold. And new arrivals get relief on foreign property: if you were not a French tax resident during the five calendar years before you moved, your real estate outside France is excluded from the IFI base through December 31 of the fifth year following the year in which you become French tax resident. During that window only French real estate counts. After it, your worldwide real estate counts.

French social charges (CSG/CRDS)

Beyond income tax, France levies social charges on many kinds of income, chiefly the CSG (contribution sociale généralisée) and the CRDS (contribution au remboursement de la dette sociale). For retirees the treatment depends on your situation, so confirm it with a professional.

In general terms, the US-source income the treaty protects, your Social Security, pension and retirement-account distributions, and US-source investment income, is not hit with these charges. For a US citizen resident in France, the same treaty credit that cancels French income tax on US-source dividends, interest, and securities gains cancels the CSG and CRDS on them as well. Where the charges can apply is on French-source or other non-US investment income, at rates up to 18.6%.

There is, however, a separate French levy the treaty does not relieve, covered next.

The PUMa health contribution (the "taxe PUMa")

Some retirees may also encounter the cotisation subsidiaire maladie under PUMa, informally the "taxe PUMa." Once you are covered by French public health insurance through residence, France can levy this contribution on your investment income, and the treaty does not relieve it, so US investment income that is free of French income tax and social charges can still be caught.

Whether it applies usually comes down to pension income: the law exempts any household where you or your spouse received a retirement pension during the year, and Americans drawing Social Security, a US pension, or regular retirement-account distributions have generally been treated as exempt on that basis. That treatment reflects administrative practice rather than an established treaty rule, so how your US retirement income is treated for this exemption should be confirmed for your circumstances. The household most clearly in scope is one living mainly off a portfolio with no pension income yet.

For 2026, it applies to a French tax resident whose earned income taxable in France is below about €9,600 and whose worldwide investment income runs above about €24,000, charged at 6.5% on the investment income above that level (both figures are indexed each year). The base is capped at about €384,000 of investment income, and one spouse drawing a pension or earning above the floor exempts both. A fuller guide to the taxe PUMa is coming separately.

Inheritance and estate planning

Estate planning is governed by a separate set of rules: the 1978 US-France estate and gift treaty, not the income treaty.

France has forced heirship (the réserve héréditaire), under which a fixed share of your estate is reserved by law for your children. This can override a US will, but it is not automatic. Under the EU Succession Regulation (Brussels IV), a US national resident in France can state in a valid will that the law of their nationality should govern their succession, which can displace French forced heirship.

There is a catch: a 2021 French law lets children cut out under the chosen foreign law claim compensation from assets located in France, up to the share French rules would have given them.

US trusts can receive very different tax and reporting treatment in France, including French trust-reporting obligations, so a revocable living trust that works in the US can behave very differently once French assets or heirs are involved.

On the tax side, French inheritance tax (droits de succession) is paid by the heir on their share, and the 1978 treaty uses situs rules and credits to prevent the same assets being taxed twice. A US person who receives more than $100,000 in qualifying gifts or bequests from a nonresident alien or foreign estate may have to report it on IRS Form 3520, even if no US tax is due. Cross-border estate planning usually involves a French notaire working with a cross-border estate advisor, a French avocat fiscaliste or a US estate attorney with French experience. What matters is that someone on the team understands both systems.

French financial structures US citizens should review carefully

Once you're settled in France, you'll likely be offered two popular French planning products. Both are common in France but can create additional US tax and reporting issues for American taxpayers.

• Assurance vie is a common French savings and estate-planning vehicle. The French tax advantages of an assurance-vie do not automatically carry over to the US, and the underlying investments can create PFIC and other US reporting issues. American retirees may encounter it soon after moving to France, and it should not be bought without cross-border advice.
• An SCI (société civile immobilière) is a French entity commonly used to hold and transfer real estate. For US citizens, holding your home in an SCI can pull you into US foreign-entity reporting (forms such as the 5471 or 8858), entity-classification questions, and ongoing compliance cost. It is occasionally still the right answer, but only after a US-aware advisor has looked at it.

What you still owe the United States

The treaty does not reduce your US filing obligations. As a US citizen in France you generally still:

• File a US federal income tax return (Form 1040) every year, reporting worldwide income.
• Report your foreign financial accounts. If the aggregate value of your non-US accounts exceeded $10,000 at any point in the year, you file an FBAR (FinCEN Form 114). Above higher thresholds you also file IRS Form 8938 under FATCA; those thresholds are substantially higher for qualifying taxpayers living abroad and vary by filing status. These are reporting forms, not extra taxes, but the penalties for missing them are severe, and an ordinary French checking account can trigger them. The $10,000 threshold is an aggregate, not per account: €6,000 in one account and €6,000 in another can cross it even though neither alone holds $10,000.
• Claim treaty benefits and credits correctly, which can involve Form 8833 to take a treaty position and Form 1116 for foreign tax credits. Form 8833 is not required for every treaty benefit, though; the IRS provides exceptions for certain categories, so don't assume you always need it or never do.

Your French filing obligations

French compliance is not only about how much tax you owe. As a French tax resident, you generally report your worldwide income each year, subject to the treaty.

The main French income-tax return is Form 2042, and foreign-source income commonly involves Form 2047 and related schedules. Separately, French residents can have their own reporting obligations for foreign bank accounts and for certain foreign investment, life-insurance, and digital-asset arrangements. This matters for Americans because your "foreign" accounts from France's perspective are your US accounts: checking, savings, brokerage, and potentially others. Reporting an account is distinct from reporting the income it produces, and an account producing no French tax does not necessarily remove the reporting obligation.

Your annual French return is generally filed in the spring for the previous calendar year's income.

Your former US state may still matter

Leaving the country does not automatically end your state tax residency. Some states, including California and New York, are often called "sticky" because they continue to treat you as a resident until you genuinely change your domicile, meaning the permanent home you intend to return to.

California's well-known "546-day safe harbor" only applies to people abroad under an employment contract, so it does not cover retirees. California considers the totality of your connections, such as your home, driver's license, vehicle registration, voter registration, bank accounts, and doctors, rather than a single checklist that ends residency.

Federal law generally prohibits a former state from taxing qualifying retirement income of a nonresident, including many pension, IRA, and qualified-plan distributions. So much of your retirement-account income is protected once you have established non-residency, and the state's reach is limited to income actually sourced there.

What to review before you move

Some of the most valuable cross-border tax work happens before you become a French tax resident. Depending on your situation, it can be worth reviewing:

• your likely French tax-residence start date;
• whether and when to sell your US home;
• any large unrealized capital gains, and planned sales of investments or employer stock;
• Roth conversions, large IRA or 401(k) withdrawals, and required minimum distributions;
• your US brokerage's policy for French residents;
• French or other non-US investments that could create PFIC exposure;
• US trusts and estate documents;
• ownership of US rental property;
• your former state's domicile requirements; and
• whether your worldwide real estate could eventually bring you into IFI.

Not every household needs to change anything. The point is to identify decisions that become harder or more expensive to change once French tax residence begins.

Who needs specialist advice?

A retiree living on Social Security and a straightforward pension can have a relatively manageable cross-border situation. Specialist planning matters much more with significant taxable investments, more than €1.3 million of real-estate wealth, US rental properties, a large gain in a US home, a trust, business interests, stock options or RSUs, substantial non-US investments, a mixed US/non-US household, a planned Roth conversion, or residence ties to more than one country.

Who can actually do your taxes?

The professional titles don't map neatly across the two countries.

• US CPA or Enrolled Agent: two US credentials. Both can prepare your US federal return and US filings, and some specialize in Americans abroad and handle FBAR, FATCA, and treaty positions well. Most won't prepare a French return or know the treaty's French-side nuances.
• Expert-comptable**:** the French chartered accountant. Many prepare individual returns and advise residents, including expatriates, on income tax, the IFI, and succession. The question is whether the person also understands US taxation and the treaty.
• Avocat fiscaliste**:** a French tax lawyer, for French tax advice, planning, and disputes, particularly anything complex or contested.

French law does not generally require an individual to use a professional to file an income-tax return. If you use separate US and French preparers, make sure they coordinate the treatment of income that appears on both returns.

So how much will you actually pay?

It depends on your mix of income and assets, and there is no meaningful universal estimate. Consider three households:

• One receives Social Security and regular 401(k) distributions. Most of its retirement income may stay primarily within the US system under the treaty, with French reporting still required.
• A second adds a large taxable brokerage account, so investment income, capital gains, foreign tax credits, and portfolio structure start to matter.
• A third owns a $2 million US home, rental properties, and a substantial portfolio and is weighing a €900,000 French home, so the home sale, IFI, estate planning, and timing of transactions become central.

All three are "American retirees moving to France," and their planning is completely different. That is why the treaty is best understood as a framework, not a tax rate.

How Aelos handles taxes after you move

Aelos Membership provides ongoing support for Americans living in France, including coordination of US and French tax filings with qualified tax professionals. Rather than a US preparer and a French preparer working from two separate versions of your financial life, we coordinate the process so the relevant information and treaty treatment are considered across both sides. Membership also covers the other recurring parts of life in France, including residence-permit renewals, healthcare administration, and banking and government correspondence.

Learn more about Aelos Membership.

This article is educational and is not tax, legal, or financial advice. Tax rules change and your situation is specific to you. Work with a qualified cross-border tax professional before making decisions.