How your US retirement income is actually taxed here.
Straight from the same profile Glidepath's engine taxes against - not a marketing summary of it.
Your US pensions, IRA/401(k), and investment income: taxed by the US. France credits its own tax on them down to about €0 (treaty Article 24), but still counts that income when setting the rate on anything France does tax - its "taux effectif" rule.
US Social Security: taxed only by the US (treaty Article 18(1)(b)) - France leaves it alone.
Income from France or other countries: taxed by France, under its normal income-tax scale (the barème) or, for investments from 2026, a 31.4% flat tax (the PFU: 12.8% income tax + 18.6% social charges). The US gives a credit, so you pay the higher of the two.
Real-estate wealth tax (IFI): applies above €1.3M, softened by a discount near the threshold (the décote). New residents pay none of it on property outside France for their first 5 years.
High-income surtax (CEHR): an extra 3-4% once your French reference income is very high.
The contested 3.8% US investment tax: whether French tax can offset it is still being fought in court (the Christensen and Bruyea cases) - toggle the assumption in the cross-border settings. Currency-shock sensitivity lives in the Resilience room.
What could change this.
Whether French tax can offset the 3.8% US Net Investment Income Tax is unsettled. Christensen (France) and Bruyea (Canada) were argued at the Federal Circuit on March 3 2026 with no ruling yet. If the government wins, you pay the 3.8% out of pocket on investment income on top of your foreign tax credit.
When: Federal Circuit ruling expected 2026
A Dec 2025 reform (Art. 53 of the 2026 Social Security finance law) replaces the ad-hoc ~6.5% CSM with an explicit capped health contribution for non-active non-EU residents on PUMa - but the amount is still to be set by decree, expected materially below 6.5%. Not yet modeled (the rate is unknown); shown for awareness.
When: Rate set by decree, 2026
New residents are exempt from the IFI real-estate wealth tax on non-French property for their first five years. After that, worldwide real estate above €1.3M is in scope. This is already reflected in your projection once you pass year five.
When: Year 6 after you move (already modeled)
Compliance traps that catch US retirees here.
Local investment wrappers that look ordinary to a local resident can be a US tax trap for a US citizen - these are the ones specific to France.
Assurance-vie is a PFIC (and maybe a foreign trust), not insurance
France's most-marketed savings product, the assurance-vie, is NOT recognized as life insurance by the IRS. Its underlying funds are PFICs (Form 8621 per fund), and some practitioners report unit-linked policies as foreign grantor trusts (Forms 3520/3520-A). French insurers virtually never issue the annual PFIC statements needed for a QEF election, pushing owners into the punitive excess-distribution regime. The treaty saving clause preserves US PFIC taxation, so the French wrapper gives no US relief. Avoid opening one.
PEA and French/EU mutual funds are PFIC traps
The PEA (plan d'épargne en actions) gives a US person no US tax benefit and holds PFICs inside a wrapper the IRS ignores. Any locally-domiciled French or EU UCITS fund (SICAV/FCP) is a PFIC. Keep investments in US-domiciled accounts/ETFs; many French banks decline US clients (FATCA), which can complicate even holding such accounts.
French social charges (CSG/CRDS, 17.2-18.6%) ARE generally creditable since 2019
After the Eshel litigation, a 2019 US-France understanding (State Dept letter, May 30 2019) established that CSG and CRDS are NOT covered by the totalization agreement, and the IRS will not challenge foreign tax credits for them - so they are now generally creditable income taxes for US persons, the opposite of the older non-creditable position. (The separate 6.5% CSM health surcharge is less settled.) LFSS 2026 raised CSG on investment income, taking those social charges from 17.2% to 18.6% (so the PFU is 31.4% from 1 Jan 2026); real-estate gains, revenus fonciers and life insurance keep 17.2%.
NIIT vs. treaty credit is contested and on appeal
In Christensen (US-France) the Court of Federal Claims rejected the Art. 24 "limitations" route but found another treaty path; the companion Bruyea case (US-Canada) squarely allowed a treaty-based foreign tax credit against the 3.8% NIIT. Treasury appealed both; the Federal Circuit heard consolidated oral argument on March 3 2026 and has not yet ruled. Treat any NIIT offset as an aggressive, unsettled position - the toggle below switches it on/off.
US Social Security exempt in France, but pushes the taux effectif
US Social Security is taxable only by the US (treaty Art. 18), so it is exempt in France, and US pensions/IRA/401(k) get a near-full French credit (Art. 24). But all that exempted income is still counted to raise the effective rate applied to any France-taxed income (e.g. French rental income).
Healthcare as a retiree.
Public PUMa (Protection Universelle Maladie / Carte Vitale): legal residents on a VLS-TS can enroll after ~3 months of stable residence; PUMa reimburses ~70% of costs and most retirees add a private mutuelle for the ~30% gap. Retirees lacking French earned income or a qualifying pension historically fell into the ~6.5% CSM band; a Dec 2025 reform (Art. 53 of the 2026 Social Security finance law) replaces it with an explicit capped contribution for non-active non-EU residents, amount still pending decree. Comprehensive private insurance (≥ €30,000 cover) is required for the first visa year.
Estimate combines a private mutuelle premium (~$1,500–2,500/person) plus the new public contribution; the first-year mandatory private policy is a separate cost. Approximate pending the 2026 contribution decree.
The retirement visa route.
VLS-TS 'visiteur' long-stay visa: stable passive income at/above the French SMIC (roughly €17,000–22,000 net/yr single, ~€20,000–25,000 per couple, prefecture-dependent) + private health insurance covering ≥ €30,000 for the first year + proof of accommodation and a signed undertaking not to work; renewable as a carte de séjour, leads to longer-term residency.
What could this actually cost you?
A fast, illustrative estimate for France - no login, nothing stored. Every country page carries its own, tuned to that country's tax treatment.
Your monthly spending power in France on about $1M
A lean lifestyle in France
Day to day, that looks like a small apartment in a lower-cost town, transit or one older economy car, cooking at home with the odd cheap meal out. For health, the public health system, with out-of-pocket costs a real worry.
As a US citizen, you keep filing US taxes wherever you live.
France: US treaty: exemption method (US retirement income taxed by the US only)
This is a fast estimate, not the full simulation, and not financial advice. It only flags the tax question. The full plan works out what you'd actually owe on each side of the border. It also models real balances, every account type, and healthcare, year by year.
The terms you'll actually run into.
- Taux effectif (effective-rate method)
- France's treaty relief mechanic: US-source income exempted under the treaty is still added back to compute your average tax rate, which is then applied only to France-taxable income (treaty Art. 24).
- VLS-TS 'visiteur'
- The long-stay visitor visa/residence permit that doubles as France’s de facto retirement visa: requires stable passive income and private health insurance, and forbids working in France.
- PUMa / Carte Vitale
- Protection Universelle Maladie, the French public health scheme (accessed via the Carte Vitale) that reimburses ~70% of costs; legal residents can join after roughly three months of stable residence.
- CSM (cotisation subsidiaire maladie)
- A means-tested health surcharge (about 6.5%) billed by URSSAF on passive/investment income for residents on PUMa who lack French earned income or a qualifying pension.
- IFI (impôt sur la fortune immobilière)
- France’s real-estate-only wealth tax on net property above €1.3M; new residents get a five-year exemption on non-French real estate.
- Assurance-vie
- France's flagship tax-advantaged investment-insurance wrapper, treated as ordinary life insurance for the French but as a PFIC (and sometimes a foreign trust) for US-person owners.
Nothing on this page is invented.
Confidence: verified. Last verified June 1, 2026. Every figure above comes from one of the sources below - the same profile the paid engine uses to actually compute your projection.
See the full country-by-country build sheet on the coverage page.