France taxes residents on worldwide income at up to 45% — yet under the 1994 US treaty, American Social Security, 401(k)s, IRAs and pensions stay taxable in the US, not France. Few countries offer that. Canadians get a different, more ordinary deal. Here's the 2026 math.
Last verified: 8 July 2026France taxes residents on worldwide income at progressive rates. These are the brackets under the Finance Law for 2026 (indexed +0.9%), applied per part:
| Taxable income per part | Rate |
|---|---|
| Up to €11,600 | 0% |
| €11,600 – €29,579 | 11% |
| €29,579 – €84,577 | 30% |
| €84,577 – €181,917 | 41% |
| Above €181,917 | 45% |
The quotient familial is the part Americans and Canadians miss: a married couple splits household income across 2 parts, taxes each half on the scale above, then doubles the result. A couple with €60,000 of taxable income is taxed as two people with €30,000 each — most of it in the 0% and 11% bands. Pension income France does tax gets a 10% deduction first (capped). Run your own numbers on the official simulator at impots.gouv.fr.
Under the 1994 US–France treaty (Articles 18/19, protocols 2004/2009), US-source retirement income — Social Security, private and government pensions, 401(k) and IRA distributions — is taxable only in the United States. You still declare it in France, and France grants a credit equal to the French tax on that income. Net effect: the income lifts the rate applied to any other French-taxable income you have, but is not itself taxed in France. Combined with the quotient familial, a US retiree couple living on retirement income can owe France little or nothing in income tax.
| United States | Canada | |
|---|---|---|
| Keep filing? | Yes — the US taxes citizens on worldwide income wherever they live. For retirees the treaty does most of the work; foreign tax credits mop up the rest. | Generally no, once you cease Canadian tax residency — but the departure tax (deemed disposition of most assets at exit) applies when you leave. Plan it before you move. |
| Treaty | 1994 treaty: US retirement income taxable only in the US; France credits the French tax. Unusually favourable — the reason France keeps appearing on US-retiree shortlists. | 1975 treaty (as amended): CPP, OAS and RRIF/RRSP withdrawals stay taxable in Canada via non-resident withholding (default 25%, reduced under the treaty); France relieves double tax by credit. Exact rates per income type: confirm with a professional. |
| Accounts reporting | FBAR if foreign accounts exceed $10,000 aggregate; FATCA Form 8938 thresholds apply. French banks report US persons under FATCA — and some refuse them as clients (see below). | Standard CRA rules until departure; exit forms (T1161/T1243 territory) on ceasing residency. |
| Social security | Totalization agreement since 1988 — no double contributions; contribution periods combine. | Canada–France and Quebec–France agreements — CPP/QPP and OAS coordinate and export. |
France charges social levies (CSG/CRDS and the solidarity levy) on investment income on top of income tax. The standard package was 17.2%; the 2026 social security financing law raised CSG on financial capital income, taking the total to 18.6% on dividends, interest and securities gains — a recent change whose exact scope is still settling in practice, so confirm it for your income types. Non-residents not affiliated to French social security pay only the 7.5% solidarity levy on French property income and gains (the De Ruyter line of cases). US retirees covered by the treaty should have the CSG question — including the IRS's position that CSG/CRDS are creditable US foreign taxes — reviewed professionally.
France's state health system is partly funded by a contribution aimed at residents who live off capital rather than work or pensions. If your professional income is below 20% of the social security ceiling (PASS) — 2026: €9,612 — URSSAF charges the cotisation subsidiaire maladie: 6.5% on capital income above half the PASS (2026: €24,030), on a base capped at 8× PASS (2026: €384,480).
Recipients of retirement pensions are exempt. One honest caveat: URSSAF's practice on foreign pensions has varied — keep your Social Security, CPP/OAS or pension award letters and payment records on file, and be ready to show them if a CSM demand arrives. Details of the healthcare system itself are in the Healthcare guide.
Because of FATCA compliance costs, some French banks refuse US-person clients — this is a practical pattern, not a legal rule. Expect extra paperwork everywhere and outright refusal at some banks and brokerages. Budget time for it, keep a US account open, and note that most French investment wrappers (assurance-vie, PEA) create PFIC headaches on the US side. Canadians face none of this friction.
Social Security, 401(k)s, IRAs and the Roth question — the treaty mechanics, worked through.
Deemed disposition, RRIF withholding under the treaty, and the timing decisions that matter.
Declaring foreign accounts, the treaty credit lines, and the May–June filing calendar.