# Move to France



## nyc.sergei (Aug 11, 2018)

Hi, I'm planing my retirement in France. I've been living and working in USA for 20 years, but I'm not an American citizen. I'm Canadian, and my retirement income will be coming for US. My questions are:
1. will I have to pay taxes to US or France or both
2. do I have a choice regarding my residency? Or living in France full time I will be considered a french resident?
Thanks for the answer. Sergei


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## Bevdeforges (Nov 16, 2007)

Chances are you'll have to file both US and French tax returns. There is no choice on that one. 

Which jurisdiction you pay to depends on a number of factors - the source of your income and the state of the current tax treaty between the US and France, among other factors.

You are considered a French tax resident if you have your primary home in France, and/or if you have your primary centers of interest in France. As far as the US is concerned, the fact of having lived there for so many years most likely makes you subject to US taxation for the duration. (I.e. as a long-term green card holder.)

Income from US Social Security and IRAs or other tax deferred retirement funds is taxable by the US (i.e. IRS). As a US taxpayer, you pay regular tax rates on that. If you meet the requirements to be considered a non-resident alien, you'll be taxes as a non-resident at a flat rate of 30%.

For the details on taxation of "US taxpayers resident overseas" take a look at IRS publication 54. 
Cheers,
Bev


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## nyc.sergei (Aug 11, 2018)

Bev, thanks for your response. Yes, I plan to live in France full time, and my only income will be coming from US Social Security, US IRA, and Canadian RRSP. I don't have a Green Card. All 20 years in US I've been working on TN and H1B visa. Do you think eventually may I be considered just a french resident? If it's the case should I still file a tax form to IRS?
And getting income from the Canadian RRSP, how will it effect my tax case?
Thanks for any info, suggestions. Regards, Sergei


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## Bevdeforges (Nov 16, 2007)

The tax rules regarding who is deemed an "overseas taxpayer" for US purposes are kind of complicated. You may want to take a look at this: https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test It may take a few years of living abroad before you're completely free of your IRS tax obligation.

And, under the US-France tax treaty, your income from the US SS and IRA are subject only to US taxes. You report them for French purposes, but then you get a credit against French tax due. Once you become a non-resident alien for US tax purposes, the tax on US pensions (i.e. SS and IRA) becomes 30% (on 85% of your US SS, on 100% of your IRA withdrawals). 

I don't know about the Canadian RRSP, but I know we have several Canadians who lurk here regularly. With luck maybe they will jump in.
Cheers,
Bev


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