Valley International / pensions
401(k), IRA and Roth accounts for US residents of France
Americans in France file in both countries every year. Retirement accounts are the part of the file where the two systems agree least, and where the paperwork is heaviest.
The United States taxes its citizens and green-card holders on worldwide income wherever they live, and France taxes its residents on worldwide income under article 4 A of the French tax code, so a US person living in France is fully within both tax bases at once. The France-United States income tax convention resolves this, and it does so in a way that is unusual: rather than removing income from one base, it generally leaves France able to tax and then relieves the double charge through a credit mechanism, which for certain US-source income is calculated so as to leave the French tax effectively neutralised. The practical effect varies by category of income, which is why retirement distributions have to be examined item by item rather than as a block.
Distributions from a 401(k) or a traditional IRA
These are the straightforward part of the file. A distribution from a US retirement plan funded with pre-tax contributions is taxable income in the United States, and the treaty determines how France treats it. Where the payment is a periodic pension it is generally analysed as pension income; where it is a single lump sum the characterisation question arises again, and article 163 bis of the French tax code may apply on express and irrevocable election, provided the payment is not made in instalments and the contributions were deductible or attached to income exempt in the state where you were then domiciled.
What matters in practice is the timing rather than the rate. A large distribution taken in the year of arrival, when the year is split between two residence periods, does not land in the same place as the same distribution taken a year later. That is a decision to take before instructing the plan administrator.
The Roth question has no settled answer
A Roth account is funded with money already taxed in the United States, and qualified distributions from it are free of US tax. France has no equivalent vehicle and no domestic rule that mirrors that exemption. Whether the French treatment follows the US characterisation, and on what basis, is not a settled question that can be answered from a page. Anyone who tells you confidently that a Roth is tax free in France is telling you what they hope rather than what they know.
The practical consequence is that a Roth conversion planned around a move to France should be modelled on both sides before it is executed, and that the position taken on the French return should be documented at the time rather than reconstructed later if it is questioned.
What you can hold, which is a narrower question than what you can afford
The retirement question sits inside a larger one. US persons in France are constrained by FATCA reporting, which leads a number of French institutions simply to decline them as clients, and by the punitive US treatment of passive foreign investment companies, which reaches most French and European collective funds. That constraint shapes what can sensibly be held inside and outside a retirement wrapper. The page US persons in France: what you can actually own sets out that framework, and it should be read alongside this one before any account is opened or restructured.
Reporting, on both sides
US reporting obligations follow the citizen and are outside this firm's remit; they are handled by a US preparer and they do not stop because you live abroad. On the French side, article 1649 A of the French tax code covers accounts opened, held, used or closed outside France, and the fine under article 1736 IV is €1,500 per account per year. Whether a given US retirement account falls within that text is a characterisation question, and the same reasoning applies as elsewhere: where the position is arguable, a declaration costs nothing and it is silence that gets sanctioned. Reporting foreign accounts, contracts and trusts in France covers the full set of French obligations that sit alongside this one.
Frequently asked questions
Will I be taxed twice on a 401(k) distribution if I live in France?
In principle no, but the mechanism is not the one most people expect. The France-United States convention generally leaves France able to tax the income and then relieves the double charge through a credit, calculated for certain US-source income so as to leave the French tax effectively neutralised, rather than by removing the income from the French base altogether. The outcome differs by category of income, so a periodic pension and a single lump sum are examined separately, on the treaty text and on the plan documents.
Is a Roth IRA tax free in France?
There is no clean answer, and anyone giving you a confident one is guessing. A Roth is funded with money already taxed in the United States and qualified distributions are free of US tax, but France has neither an equivalent vehicle nor a domestic rule mirroring that exemption. Whether the French treatment follows the US characterisation is genuinely open. A Roth conversion timed around a move to France should therefore be modelled on both sides before it is executed, and the position taken should be documented at the time.
Should I take a lump sum before or after moving to France?
Timing usually matters more than any rate. The year of arrival is split between a non-resident period and a resident one, and a large distribution falls on one side or the other depending on the day it is paid. A payment made while still non-resident, a payment made in the year of arrival, and a payment made the following year produce three different files. The decision should be taken before the plan administrator is instructed, because once the payment is made the facts are fixed.
Can I invest in French funds through my French accounts as a US person?
Rarely without cost. Most French and European collective investment funds are passive foreign investment companies for US tax purposes, and that regime carries reporting and taxation heavy enough to erase the return. Separately, FATCA reporting leads a number of French institutions to decline US persons as clients outright, so opening an account is often the first practical obstacle rather than the last. The page US persons in France: what you can actually own sets out which structures survive that filter.
Do I still have to file in the United States while living in France?
Yes. US filing obligations follow citizenship and green-card status rather than residence, and they continue for as long as that status does, regardless of where you live or where the income arises. Those obligations, including any reporting of foreign accounts and assets, are handled by a professional authorised in the United States. This firm advises on the French side and coordinates with your US preparer; it does not provide US tax advice and does not replace them.
ÉTHIQUE ET PATRIMOINE, a French simplified joint-stock company (SAS), registered office at 41 rue Saint-Ferdinand, 75017 Paris, France, Paris Trade Register no. 803 414 796, VAT no. FR 40 803 414 796, registered with ORIAS under number no. 24001817 (www.orias.fr) — Financial investment adviser (CIF) no. 18002418, member of ANACOFI-CIF, a professional association approved by the Autorité des marchés financiers, and Anacofi-Courtage for its brokerage activity. Presence: Paris, Montpellier, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.
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Book a callWritten by Stéphane Molère, Président d'Éthique et Patrimoine — page last reviewed on 2026-08-30 — rules quoted are those in force at that date.