The Expat Sage Podcast

Tax-Smart Move To France

The Expat Sage

Planning a move to France with U.S. retirement accounts can feel like threading a needle in a storm—until you know exactly where the thread goes. We break down the cleanest path for dual-citizen couples to establish residency, safeguard 401(k) and IRA distributions from double taxation, and keep long-term investing on track without getting blindsided by brokerage restrictions or surprise social charges.

First, we walk through the conjoint de Français visa and the three-month online validation that quietly converts a visa into a residence permit. From there, we connect the 183-day residency rule to worldwide reporting and explain why your U.S.-sourced retirement income still appears on French forms even when treaty rules apply. Article 18 of the U.S.–France tax treaty is the anchor: it assigns U.S. tax rights over U.S.-sourced pensions and Social Security, shielding those distributions from French income tax while still influencing your French effective rate on other income.

Then comes the twist that trips up many retirees: France levies CSG and CRDS social charges, typically around 9.1%, on pension income. What looks like double taxation becomes solvable once you know the IRS recognizes those charges as creditable foreign taxes. We detail how to use Form 1116 to claim the credit against your U.S. liability, including a clear $50,000 example that shows the French payment effectively prepaying your U.S. tax. We also cover what’s not a problem (IFI wealth tax generally excludes securities and U.S. retirement accounts) and what can be a major headache: U.S. brokerages that restrict clients with foreign addresses. You’ll hear the practical steps to confirm policies in advance and migrate to an expat-ready platform if necessary.

We round out the playbook with U.S. compliance essentials—annual filing, FBAR thresholds, and FATCA Form 8938—and a special note on Roth accounts, which need cross-border expertise to preserve favorable treatment. If you’re mapping a France move with U.S. retirement savings, this guide shows how residency rules, treaty protections, and the foreign tax credit can work together rather than against you. If this helped clarify your plan, subscribe, share with a friend who’s France-bound, and leave a review telling us your biggest open question so we can tackle it next.

More info at Relocating to France for dual-citizenship couples with U.S. retirement assets (https://investingforexpats.com/fr/relocating-to-france-for-dual-citizenship-couples-with-us-retirement-assets)

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Moving, Working, and Investing for Americans Abroad