How is my US 401(k) or IRA taxed once I live in France?
Short answer: It depends on your citizenship. For a French resident who is not a US citizen or green card holder, the US–France treaty makes 401(k) and Traditional IRA distributions taxable only in France, while US Social Security is taxable only in the US. US citizens living in France are taxed by both countries, and Article 24 of the treaty gives them credits so they are not taxed twice.
Written and reviewed by Anthony Walsh, Selanis. Last reviewed 2026-10-06.
Why it works this way
Article 18 of the treaty is the key. Private 'pensions and other similar remuneration' paid to a French resident are taxable only in France, so a returning French national claims the treaty exemption from US withholding (Form W-8BEN with the plan custodian) and pays French income tax instead. US Social Security goes the other way: it is taxable only in the US.
In practice, your US Social Security is added to your French income only to set your tax rate (taux effectif); you don't pay French income tax on it. Your 401(k) and IRA withdrawals, by contrast, are taxed in France as pension income. French social charges on foreign pensions depend on whether France covers your healthcare, so check them before you start drawing.
Roth IRAs are more ambiguous. The French tax authorities do not have a formal, public position that recognizes a Roth IRA as a 'pension.' As a result, there is a risk that France could tax the dividends and capital gains within the Roth annually, or tax the distributions, unlike the US where they are tax-free.
The expensive mistake: Assuming 'tax-free' in the US means 'ignored' in France
Even if your US pension is not taxed in France due to the treaty, you MUST still declare it on your French tax return (Forms 2042 and 2047). Failure to report foreign income is a serious offense in France and can lead to the loss of treaty benefits and significant penalties.
What to do
- File Form 2047 and 2042 annually — Report your US pension income on these forms to ensure you receive the treaty-mandated tax credit in France.
- Review the 'Article 24' credit mechanism — If you are a US citizen, make sure your adviser applies the Article 24 credits correctly. If you are not, make sure the US custodian is not withholding 30% that the treaty says it shouldn't.
- Check your 'Social Charges' exemption — If you are not covered by the French social security system (e.g., you have private US insurance), you may be able to avoid CSG/CRDS on your US pension.