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.
US and Canadian tax obligations don't stop at the border. We'll match you with a cross-border tax adviser we've checked ourselves — credentials, licensing, and real client outcomes in France.