France generally does not tax US pensions in the hands of an American retiree living there, but the reason differs by pension type. US Social Security is taxable only in the United States under the tax treaty. Distributions from 401(k)s, IRAs, and similar private retirement accounts are technically taxable in France, but France grants a credit that cancels the French tax. Federal, state, military, and other US government service pensions stay taxable only in the US. In every case, the income still has to appear on your French return, and it can affect the rate applied to your other French income or trigger separate social charges.
US Social Security Benefits
Social Security payments fall under Article 18(1)(b) of the US-France treaty, which assigns taxing rights to the country paying the benefit.1Internal Revenue Service. Convention Between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation If you live in France and collect US Social Security, only the United States taxes it. France cannot.
You still have to declare the income on your French return. France uses it through the “taux effectif” method, which factors your worldwide income into the rate applied to your French-source income. The Social Security payment itself is not taxed, but it can raise the rate on French rental income, investment gains, or other French earnings.
401(k)s, IRAs, and Other Private Pensions
Distributions from 401(k) plans, 403(b) accounts, traditional IRAs, and similar arrangements fall under Article 18(1)(a). The treaty text makes these payments taxable in the country where the recipient resides, which for an American in France is France.1Internal Revenue Service. Convention Between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation Because you are a US citizen, the IRS still expects you to report and pay US tax on the same distributions.
Article 24 resolves the overlap. France includes the distribution in your total income calculation and then grants a tax credit equal to the French tax that would otherwise apply to it.1Internal Revenue Service. Convention Between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation The credit erases the actual French tax bill on the pension, so you are not paying French income tax on money the IRS has already taxed.
There is a wrinkle. France applies “exemption with progression,” meaning your US pension is added to total income to determine which bracket applies to your other French earnings. A 401(k) distribution generates no French tax bill of its own, but it can push French rental income or other French-source income into a higher bracket. Retirees with mixed income sources are often caught off guard by this at filing time.
Roth IRA Distributions
Roth IRAs sit in an awkward place. The US treats qualified distributions as tax-free, and France has no equivalent account. The Treasury Department’s Technical Explanation of the 2004 Protocol confirms that Roth IRAs under section 408A are individual retirement plans eligible for treaty benefits.2U.S. Department of the Treasury. Technical Explanation of the Protocol Between the United States of America and the French Republic Signed at Washington on December 8, 2004 A 2020 response from the French Ministry of Economy took the same position, stating that distributions from American retirement plans are taxable only in the United States under Article 18(1).
Applying that in practice is messier. Some French tax offices have treated Roth distributions as ordinary investment income rather than pension income, especially when the filer could not document the account’s status. Keep a copy of the Technical Explanation and account statements showing the Roth designation. A local advisor familiar with both systems is often worth the fee, because a misclassification means France may tax the full distribution as ordinary income.
Federal, Military, and Other Government Service Pensions
Pensions paid to former employees of the US federal government, state governments, or local authorities follow Article 19(2)(a) rather than Article 18. These pensions are taxable only in the United States, regardless of where the retiree lives.1Internal Revenue Service. Convention Between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation Federal civil service retirees, military retirees, former state employees, and retired public school teachers drawing a government pension all fall under this rule.
One narrow exception: if the recipient is a French national and French resident who is not also a US citizen or permanent resident, France gains the right to tax the government pension.1Internal Revenue Service. Convention Between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation For almost every American retiree in France, this does not apply, and the US stays the sole taxing authority.
Social Charges and the Healthcare Contribution
Income tax is only part of the picture. France applies separate social charges, and these can reach retirees whose pension income is exempt from French income tax under the treaty.
CSG and CRDS
The two main social charges are the CSG (general social contribution) and the CRDS (social debt repayment contribution). Residents affiliated with a compulsory social security system in an EU or EEA country, or Switzerland, are exempt. The United States is not in that group, so Americans in France do not automatically qualify. Whether CSG and CRDS reach your US pension depends on how France classifies the income and whether you are enrolled in the French social security system. If the pension is fully exempt from French income tax under the treaty, France’s basis for applying social charges to it is generally limited, but the rules are complex enough to warrant professional guidance.
The Healthcare Contribution (CSM)
France’s universal health system (PUMa) charges a supplemental “cotisation subsidiaire maladie” (CSM) to residents with significant passive income and little or no employment income. For 2026, the CSM runs at approximately 6.5% of worldwide passive income above €24,030 for a single person or €48,060 for a couple, capped once income reaches €384,480. Residents earning more than €9,612 in employment or self-employment income are exempt.
US Social Security recipients may qualify for an exemption, though that reading has not been guaranteed to hold. If your income is a US pension plus Social Security, the CSM can be a meaningful charge many retirees do not build into their budget.
Reporting US Pension Income on Your French Return
Even when France cannot tax your pension, the income has to appear on your return. The core form is the Déclaration des revenus (Form 2042), the standard French income tax return.3Ministère de l’Économie, des Finances et de la Souveraineté industrielle et numérique. Formulaire 2042 – Déclaration des revenus You also file Form 2047 for income earned outside France.
The right box depends on the pension type. For private pension distributions that receive the Article 24 credit, the gross amount goes on Form 2047 and transfers to line 8TK on Form 2042, which drives the credit calculation. For pensions used only to set the effective rate, such as Social Security, the French tax authority directs filers to lines 1AC and following on Form 2042C rather than line 8TK.4impots.gouv.fr. Taxation of Income Received Abroad Each box triggers a different calculation, so the placement matters.
Filings go through impots.gouv.fr.5impots.gouv.fr. Services For 2026, the online deadline for non-residents and residents in departments 01 through 19 is May 21, with later zones closing May 28 and June 4. Paper returns are due May 19.6service-public.gouv.fr. 2025 Income Tax Return – What Is the Deadline in Your Department
US Filings You Still Owe
Living in France does not release you from US filing duties, and the penalties on the American side can dwarf anything on the French side.
FBAR (FinCEN Form 114)
If you have a financial interest in or signature authority over foreign accounts whose combined value exceeds $10,000 at any point in the year, you must file a Report of Foreign Bank and Financial Accounts.7Internal Revenue Service. US Citizens and Residents Abroad – Filing Requirements That covers French checking, savings, and investment accounts. The report is filed electronically through the FinCEN BSA E-Filing System, separately from your tax return. Non-willful violations can draw penalties up to $10,000 per report; willful failures carry the greater of $100,000 or 50% of the account balance at the time of the violation.8Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties
FATCA (Form 8938)
US citizens abroad face a separate FATCA requirement. File Form 8938 if you are unmarried and your foreign financial assets exceed $200,000 on the last day of the tax year or $300,000 at any point during the year. For joint filers, the thresholds are $400,000 and $600,000.9Internal Revenue Service. Summary of FATCA Reporting for US Taxpayers Form 8938 goes with your tax return. Many retirees in France file both the FBAR and Form 8938; the two have different thresholds and cover overlapping but not identical accounts.
Foreign Tax Credit on Your US Return
Where France does collect tax, whether through social charges or tax on French-source earnings, you can claim a foreign tax credit on your US return with Form 1116.10Internal Revenue Service. Foreign Tax Credit The IRS has stated that French CSG and CRDS may qualify as creditable foreign taxes. The credit offsets US tax dollar-for-dollar, up to the amount of US tax attributable to the foreign-source income.