Moving to France is one of the great life decisions. The food, the pace, the culture, the countryside. But tucked inside that move is a set of financial decisions that most Americans do not discover until after they have already left. Your 401(k), your IRA, your Roth, your old 403(b) from a previous employer: none of them disappear when you cross the Atlantic. What changes, sometimes significantly, is how they are treated, reported, and taxed on both sides of the ocean.

The good news is that the France-US Tax Treaty contains one of the most favorable retirement account provisions of any US bilateral treaty in the world. Understanding it, and acting on it before you establish French tax residency, can save you a very substantial amount of money over the course of a retirement spent in France.

This guide covers the full picture: what happens to each type of US retirement account when you move to France, how the treaty protects you, what French reporting obligations kick in, and the key planning moves to make before you go.

Your US Retirement Accounts: A Quick Recap Before Crossing the Atlantic

Most Americans heading to France arrive with some combination of the following. Understanding what each one is, and how each one will be treated under French law, is the foundation of everything that follows.

Account Type	Contribution Basis	US Tax on Withdrawal	RMD Required?
Traditional 401(k)	Pre-tax	Ordinary income tax	Yes, from age 73 or 75
Traditional IRA	Pre-tax (usually)	Ordinary income tax	Yes, from age 73 or 75
Roth IRA	After-tax	Tax-free (qualified)	No (owner’s lifetime)
Roth 401(k)	After-tax	Tax-free (qualified)	No (post-SECURE 2.0)
403(b) / 457(b)	Pre-tax	Ordinary income tax	Yes, from age 73 or 75
SEP IRA / SIMPLE IRA	Pre-tax	Ordinary income tax	Yes, from age 73 or 75

2026 contribution limits: 401(k) elective deferrals $24,500 ($32,500 with age 60-63 catch-up); IRA limit $7,500 ($8,600 if age 50 or older). RMDs required beginning at age 73 for most pre-tax accounts under SECURE 2.0.

The France-US Tax Treaty: A Rare and Powerful Benefit for Retirement Accounts

Article 18 of the France-US Income Tax Treaty is one of the most important provisions for American retirees living in France, and one of the least understood. The article provides that distributions from US pension plans and retirement accounts made to a French resident are taxable only in the United States. France effectively agrees to step aside and let the US handle the taxation of these distributions. You can find further technical details in the IRS guidance on the taxation of foreign pension and annuity distributions.

This is genuinely unusual. Many other US tax treaties do not contain this protection. Americans retiring in Portugal, Spain, or other European countries may find that their Traditional IRA distributions become subject to local income tax on top of US obligations, whereas France’s treaty helps avoid double taxation that might otherwise arise alongside local taxes. France’s treaty is comparatively protective; French income tax rates generally range from 0% to 45%, which makes that protection especially valuable for retirees with sizable US distributions, and it is one reason France can be a genuinely tax-efficient destination for Americans with significant US retirement savings.

What the Treaty Covers

The treaty protection under Article 18 applies broadly to US-sourced pension and retirement income received by French residents, including distributions from:

• Traditional 401(k) plans
• Traditional IRAs
• 403(b) plans and 457(b) governmental plans
• SEP IRAs and SIMPLE IRAs

Roth IRA Distributions: Opportunities and Uncertainties

While the France-US Tax Treaty generally allocates taxing rights over retirement distributions to the United States, the treatment of Roth IRAs remains a nuanced area of cross-border planning. Strategically, a Roth conversion can be a powerful tool for long-term tax efficiency; however, these conversions are significantly simpler to execute effectively before you establish French tax residency. Once you are within the French tax system, the administrative and tax complexity of such moves increases substantially.

It is important to note that while many interpret the treaty as rendering qualified Roth distributions tax-free in both countries, the specific application of treaty provisions can contain areas of uncertainty and varying interpretations by tax authorities. Because of these potential complexities, any decisions regarding Roth IRA distributions or conversions should be made only after a thorough, coordinated review with a qualified cross-border financial advisor to ensure your strategy aligns with the most current legal and treaty interpretations.

Treaty alert: The US savings clause means that, as a US citizen, you remain subject to US worldwide tax regardless of treaty provisions. But the treaty still matters: it prevents France from layering its own tax on top of the US tax you already owe, effectively capping your total tax burden on retirement distributions at the US rate.

French Reporting Obligations: What You Must Declare Every Year

The treaty protects you from double taxation on distributions. But it does not eliminate your French compliance obligations. From the moment you become a French tax resident, your US retirement accounts are subject to French disclosure requirements, and the penalties for non-disclosure are not trivial.

Form 3916: Declaring Foreign Accounts

Every French tax resident must declare all accounts held at financial institutions outside France on Form 3916 (Declaration par un resident d’un compte ouvert hors de France), filed as an annex to the standard French income tax return, Form 2042. A separate Form 3916 entry is required for each account, even if no distributions were taken during the year. Official guidance is provided by the French Tax Authority on declaring foreign accounts.

Your US 401(k), Traditional IRA, Roth IRA, and any other US-held retirement account are all considered foreign accounts from France’s perspective. Each one must be declared each year you are a French tax resident. The form requires the institution name, country, account number, and account type. It is a disclosure form, not a taxation trigger, but failing to file it can result in per-account penalties under French law.  A small incentive to consolidate accounts as much as possible before moving.

Critical point: Form 3916 and the US FBAR (FinCEN Form 114), the Foreign Bank Account Report, are entirely separate obligations. Filing one does not satisfy the other. Form 3916 covers your French obligation to disclose foreign accounts. FBAR covers your US obligation to report foreign financial accounts, and Americans must report foreign accounts over $10,000 to the IRS under those rules. Your US retirement accounts held at US institutions are not subject to FBAR, but they are subject to Form 3916 as a French resident. Make sure your tax adviser understands both sides of this, including when US reporting of foreign assets may also trigger FATCA-style disclosures separate from Form 3916.

Your French Income Tax Return

US retirement distributions received while you are a French tax resident must still be declared on your French income tax return as part of broader French taxation of residents, even where the treaty overrides French taxation on that specific income. France taxes residents on worldwide income and uses the return to assess the tax implications for other income taxes and treaty relief. France needs to see the income in order to apply the treaty credit mechanism correctly and determine how it interacts with your overall French tax bracket. Declaring does not mean paying French tax on the amount, but failing to declare creates a compliance gap, while proper reporting helps satisfy cross-border tax obligations on both the French and U.S. sides.

What to Do with Your 401(k) When You Leave US Employment

If you are leaving a US employer to move to France, your 401(k) plan requires a decision. You have three main options, and the right one depends on your personal situation, the size of the account, and your planned drawdown timeline.

Option 1: Leave It in the Plan

Leaving the 401(k) in your former employer’s plan is the simplest option in the short term. Most plans allow terminated employees to remain as account holders indefinitely, provided the balance exceeds the plan’s mandatory cash-out threshold, which SECURE 2.0 raised to $7,000 for distributions after 2023. The account continues to grow tax-deferred and you do not need to report it to France until distributions begin, though annual Form 3916 disclosure is still required.

The practical downsides of leaving the account in a former employer plan are worth weighing. Investment options may be limited, and you may face additional administrative fees. Some plan administrators become less accommodating toward overseas account holders over time. If the employer is acquired or restructures the plan, you may be forced to take action at a moment not of your choosing.

Option 2: Roll to a Traditional IRA

Rolling your 401(k) to a Traditional IRA is the most common choice for departing employees, and it makes good sense for most situations. A direct trustee-to-trustee rollover is non-taxable and gives you significantly more investment flexibility, easier ongoing management, and a consolidated account you control directly. There is no withholding if the rollover is done correctly as a direct transfer, and there is no limit to the number of direct trustee-to-trustee transfers that can be completed in a year.

From a France-US treaty perspective, Traditional IRA distributions are treated identically to 401(k) distributions: taxable only in the US under Article 18. So rolling from a 401(k) to a Traditional IRA does not change your French tax position but can greatly simplify your investment portfolio.

Option 3: Take a Distribution (Almost Always the Wrong Move)

Cashing out your 401(k) when leaving the US is almost always the most expensive option. The full distribution is taxed as ordinary income at your marginal US rate. If you are under 59½, a 10% early withdrawal penalty may apply on top. For a large account, this can represent a loss of 30% to 40% or more of the total value. In general this option is unadvised without specific and compelling reasons.

Can You Still Contribute to an IRA While Living in France?

This is one of the most frequently misunderstood aspects of retirement planning for American expats. The short answer is: it depends on your income structure and how you handle the Foreign Earned Income Exclusion. 

It is also worth noting that the primary benefit of a Traditional IRA is the ability to defer current tax liability on contributions, which is particularly valuable when your tax liability is high. If you have no or very low US tax liability, that deferral may not make sense; obviously, this consideration does not apply to a Roth IRA, which offers no immediate tax deduction. You can read more about the specifics of an Individual Retirement Account (IRA) for Expats here.

The FEIE Problem

The Foreign Earned Income Exclusion (FEIE) allows US citizens living abroad to exclude up to $132,900 of foreign earned income from US federal tax in 2026. This is enormously valuable for expats with overseas employment income. But there is a catch: any income excluded under the FEIE cannot be used as the basis for IRA or ROTH contributions. You can only contribute to a Traditional IRA or Roth IRA based on earned income that was not excluded.

If you use the full FEIE and have no remaining earned income after the exclusion, you cannot contribute to an IRA or ROTH at all that year. If you have earned income above the exclusion threshold, you can contribute based on that excess, up to the annual limit.

The Foreign Tax Credit Alternative

Some expats in France choose to use the Foreign Tax Credit (FTC) instead of, or in combination with, the FEIE. Unlike the FEIE, the FTC does not exclude income from your return. It provides a dollar-for-dollar credit against US tax for French taxes paid on the same income. It is also one of the main tax benefits for eligible expats trying to reduce overlapping US and French income taxes. Using the FTC keeps your income on the US return as eligible compensation for IRA purposes, preserving contribution eligibility. For Americans in France, where income tax rates are generally higher than in the US, the FTC often generates excess credits that fully offset US tax liability anyway. Whether FEIE or FTC is the right strategy for your situation depends on your income level, income type, and French tax position.

2026 IRA Contribution Limits

Traditional IRA and Roth IRA: $7,500 per year, or $8,600 for those age 50 and older (the additional $1,100 is the catch-up contribution). Roth IRA contributions phase out for higher earners at modified adjusted gross income above $236,000 for married filing jointly and $150,000 for single filers in 2026.

The Pre-Move Roth Conversion: Potentially the Most Valuable Move You Will Make

For Americans who are planning a move to France and have significant pre-tax retirement balances, a Roth conversion strategy executed before establishing French tax residency deserves very serious consideration. This is an area where proactive planning before you leave the US can deliver benefits that compound for decades.

Why Convert Before Moving?

A Roth conversion involves paying income tax on a pre-tax retirement account balance today, moving those funds into a Roth IRA where they can grow tax-free and generate tax-free qualified distributions for the rest of your life. Executing this strategy before you move to France offers significant administrative simplicity, as you are only managing the transaction under US tax rules while you are a US resident.

Beyond simplicity, the power of a Roth conversion lies in the long-term tax efficiency of the Roth account structure itself. Converting while you are a US resident allows you to streamline the process, avoiding the potential complexities of cross-border tax characterization once you are within the French tax system. While the France-US Tax Treaty provides favorable treatment for US retirement accounts, the specific application of treaty provisions—particularly regarding Roth conversions and qualified distributions—can contain areas of nuance and varying interpretations. Because of these potential complexities, any decisions regarding Roth IRA conversions should be made only after a thorough, coordinated review with a qualified cross-border financial advisor.

How Much to Convert and When

The optimal strategy involves converting enough each year to fill lower US tax brackets without pushing your income into higher brackets. Working with a qualified financial advisor is essential to ensure these conversions are executed in a tax-efficient manner, maximizing your tax bracket management and minimizing your total lifetime tax liability.

Pre-move checklist: If you are planning a move to France within the next one to three years and you hold significant pre-tax retirement balances, model a Roth conversion strategy now. The window before French tax residency begins is finite and valuable. Once you are resident in France, the conversion calculus changes significantly.

Required Minimum Distributions: Planning Distributions from France

Once you reach age 73 or 75 (depending on your birth year), the IRS requires you to take Required Minimum Distributions (RMDs) from Traditional IRAs, 401(k) plans, and most other pre-tax retirement accounts. This obligation does not go away because you live in France. RMDs are calculated each year based on your account balance as of December 31 of the prior year divided by a life expectancy factor from IRS tables.

From a US tax perspective, RMDs are taxable as ordinary income in the year received. From a French perspective, under Article 18 of the treaty, these distributions are taxable only in the US. They must still be disclosed on your French tax return but should not generate a French income tax liability.

Roth Accounts and RMDs

One of the most significant benefits of a Roth IRA for long-term retirees in France is that Roth IRAs have no RMD requirement during the original owner’s lifetime. This means the account can continue to grow tax-free indefinitely, giving you full control over timing and size of withdrawals. Roth 401(k) accounts also eliminated lifetime RMDs for original owners under SECURE 2.0.

For a retirement that could span thirty or more years in France, the ability to control the timing of Roth distributions rather than being forced to take mandatory annual withdrawals is a genuinely meaningful planning tool.

Managing the RMD Income Stream in France

For Americans in France whose RMDs are substantial, there is an important consideration around how that income interacts with the French tax system, even when Article 18 allocates taxing rights to the US. Large US retirement distributions that must be declared on the French return can influence how other income streams are taxed in France, including investment income. A cross-border adviser can help you model the annual income flow from RMDs and optimize the interaction with your French tax return.

The Pre-Move Action Plan: Key Steps Before You Establish French Tax Residency

The most effective retirement account planning for Americans retiring in France happens before you arrive, not after. Here is a practical checklist of the decisions and actions worth addressing in the one to three years before your departure. Before any of that works in practice, Americans staying over 90 days generally need a long stay visa; the application fee is generally €99, it must be validated within 3 months of arrival, and longer-term legal stay then moves into residence permit and residence permits formalities.

Review Every Account You Hold

Make a complete inventory: account type, custodian, balance, and current beneficiary designations. Outdated beneficiaries are one of the most common and costly oversights in estate and retirement planning for expats.

CRITICAL: Confirm Custodian Policies for Overseas Accounts

Do not skip this step. Not all US brokerage firms and IRA custodians are comfortable servicing accounts for overseas residents. Some will restrict trading, while others may be forced to close your accounts entirely upon discovering you reside abroad. You must explicitly confirm your custodian’s policy regarding overseas residents before you move. If your current provider does not welcome expatriate clients, you should transfer your assets to a custodian that actively services overseas residents while you are still a US tax resident.

Decide What to Do with Employer Plans

If you will be leaving US employment, decide before you depart whether to leave the 401(k) in the plan or roll it to a Traditional IRA. A direct rollover executed cleanly before your French tax residency begins avoids any ambiguity around how the rollover is treated in France.

Get a Coordinated US-French Investment Management Strategy

A coordinated US-French approach to investment management is essential for anyone with significant retirement assets making this move. Working with an advisor who possesses a deep understanding of the cross-border landscape, including how investment and account-access issues can differ if you are treated as a US person abroad, a foreign national in France, or share planning considerations with French citizens in your household, ensures that your portfolio strategy, from asset allocation to specific account structures, aligns with the realities of life in France.

A critical part of this service is proactive tax modeling, such as evaluating potential Roth conversion scenarios. If you have significant pre-tax balances, your advisor can run multi-year projections that account for your expected US federal tax bracket, your state’s tax treatment of conversions, and the long-run benefit of tax-free distributions in France. Because the interplay between your US accounts and the French financial environment is so nuanced, generic investment guidance from either side of the Atlantic is rarely sufficient to build a truly robust, long-term plan.

Plan Your First French Filing

From your first year as a French tax resident, you are required to file Form 3916 for every US retirement account you hold. Make sure your French tax adviser knows about every account from day one. Penalties for undisclosed foreign accounts are assessed per account and can accumulate quickly.

FAQs – U.S. Retirement Accounts When Moving to France

Does France tax my 401(k) and IRA distributions?

Under Article 18 of the France-US Tax Treaty, distributions from US pension and retirement accounts made to French residents are taxable only in the United States. France does not impose income tax on these distributions. You must still declare them on your French tax return, but they should not generate a French income tax liability when the treaty is applied correctly.

Are Roth IRA withdrawals really tax-free in France?

Qualified Roth IRA withdrawals are tax-free in the US. However, in France the specific application of treaty provisions can contain areas of nuance and varying interpretations by tax authorities. Because of these complexities, any decisions regarding Roth IRA distributions should be made only after a thorough, coordinated review with a qualified cross-border financial advisor to ensure your strategy aligns with current legal interpretations.

What is Form 3916 and do I really need to file it?

Form 3916 is the French declaration form for foreign accounts held by French tax residents. You are required to file a separate entry for each US retirement account you hold, even if you took no distributions during the year. Non-disclosure can result in per-account penalties. It is a disclosure requirement, not a tax trigger, but it is mandatory.

Can I still contribute to my Roth IRA after moving to France?

It depends on your income structure. If you use the Foreign Earned Income Exclusion and exclude all or most of your earned income, you may have insufficient eligible compensation for IRA contributions. If you use the Foreign Tax Credit instead, your income remains on your US return as eligible compensation. Many expats in France find the FTC approach preserves IRA contribution eligibility while still delivering effective double-tax relief.

Should I do a Roth conversion before moving to France?

Roth conversions are possible both before and after moving to France, but the administrative and tax complexity often increases significantly once you are a French tax resident. Converting before you leave allows you to manage the process under US tax rules while you are a US resident. Because the application of the France-US Tax Treaty to conversions and distributions can be nuanced and subject to interpretation by tax authorities, you should consult with a qualified cross-border financial advisor to model your specific situation before making any decisions.

What happens to my IRA when I die if I live in France?

US IRA assets pass by beneficiary designation. For French-resident beneficiaries, US income tax on distributions will apply as they are taken, and French inheritance tax (droits de succession) may also apply depending on the beneficiary’s relationship to the deceased and the applicable treaty provisions. The US-France estate tax treaty provides certain protections but does not eliminate all French inheritance tax exposure. This is an area that requires careful estate planning; for more detailed information on navigating cross-border succession, please refer to our guide, ‘Estate Planning for Americans in France: Wills, Succession Law, and Protecting U.S. Assets’.

My 401(k) custodian says they cannot service overseas accounts. What do I do?

This is a common problem. Your options are to roll the 401(k) to a Traditional IRA with a custodian that actively serves expatriates before you depart, or to consolidate accounts with a US-based provider known to accommodate overseas clients. Doing this before your move, while still a US resident, is cleaner administratively than trying to manage an account transfer from France.

Moving to France with US Retirement Accounts? The decisions you make before boarding that plane can shape your retirement incomefor decades. At Harrison Brook USA, we specialize in helping Americansnavigate the France-US financial corridor with confidence and clarity. From Roth conversion modeling to French Form 3916 compliance, we handle the complexity so you can focus on the adventure. Book your free initial consultation today.

Disclaimer: This article is for informational purposes only and does not constitute financial, tax, or legal advice. Tax rules in both the United States and France change frequently and individual circumstances vary significantly. Please consult a qualified cross-border financial adviser and tax professional before making any decisions related to retirement accounts, Roth conversions, or relocation planning.