Are French disability pensions taxable for US citizens if already taxed in France?
I'm a US citizen who moved to the States about 8 years ago from France. I've been receiving a French disability pension for the last several years due to a work accident I had while still living in France. I pay taxes on this income in France as required, but I'm really confused about whether I need to report and pay taxes on this same income in the US. My disability pension is about 18,500 euros annually (around $20,000), and France already takes about 15% in taxes. I've been filing US taxes as required since moving here, but honestly, I never thought to include this French pension since it's already taxed over there. My brother recently mentioned something about foreign income reporting, and now I'm worried I might have been doing my taxes wrong all this time. Do I need to report this income on my US tax return? And if so, is there some kind of credit for taxes I've already paid to France so I'm not double-taxed? I'd really appreciate any guidance on this. I'm trying to get all my documentation in order before the upcoming tax season.
20 comments


Adaline Wong
You definitely need to report your French disability pension on your US tax return. As a US citizen, you're required to report your worldwide income, regardless of where it's earned or paid. The good news is that you likely won't end up paying tax twice on the same income. The US-France tax treaty has specific provisions for pensions, and you can also take advantage of the Foreign Tax Credit by filing Form 1116 with your tax return. This credit allows you to offset your US tax liability with the taxes you've already paid to France. I would recommend looking at the specific classification of your disability pension under the tax treaty, as some disability payments might qualify for special treatment depending on why they're being paid and how they're classified under French law. You should also look into filing amended returns (Form 1040-X) for previous years if you haven't been reporting this income. There's generally a 3-year statute of limitations for amending returns, but it's best to get compliant as soon as possible.
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Gabriel Ruiz
•Thank you for the information! Do you know if there are penalties for not reporting this in previous years? And should I use a tax professional who specializes in international tax issues or can I handle this myself with tax software?
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Adaline Wong
•There can be penalties for not reporting foreign income, but the IRS has programs like the Streamlined Filing Compliance Procedures that may help minimize penalties if you voluntarily come forward before they contact you. Since you weren't aware of the reporting requirement, you may qualify for reasonable cause relief as well. I would strongly recommend working with a tax professional who specializes in expatriate taxes or international taxation for at least the first year. They can help ensure you're properly applying the tax treaty provisions and correctly completing Form 1116 for the Foreign Tax Credit. They can also advise you on the best approach for addressing any prior year non-compliance. The complexity of international tax situations often exceeds what most consumer tax software can properly handle.
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Misterclamation Skyblue
I went through something similar with my German pension last year. I spent hours trying to figure out all the forms and got so frustrated with contradicting information online. Then I found this amazing AI tool called taxr.ai (https://taxr.ai) that literally saved me during tax season. You upload your tax documents and pension statements, and it analyzes everything according to the specific tax treaty between the US and France. It identified exactly which sections of my foreign pension were taxable in the US and which weren't (there's a difference!). It even figured out the exact Foreign Tax Credit I was eligible for and prepared all the forms I needed. The best part was that it explained everything in simple language, not tax jargon. It walked me through each step for reporting my foreign pension correctly.
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Peyton Clarke
•How accurate was it compared to what an accountant would do? I've got UK pension income and I'm paying a fortune to an international tax specialist every year. Would this handle the FBAR reporting too?
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Vince Eh
•I'm a bit skeptical about AI tools for complex international tax situations. Does it actually know all the details of different tax treaties? My situation involves Spanish disability payments and Social Security, and every accountant I've talked to has given me different answers.
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Misterclamation Skyblue
•The accuracy was impressive - I actually had my accountant review what taxr.ai prepared, and he said it was spot-on for my German pension situation. He was surprised at how it correctly applied the specific clauses in the US-Germany tax treaty that applied to my type of pension. It does handle FBAR reporting requirements as well. It identified which of my foreign accounts needed to be reported and generated the necessary forms with all the right information. For complex situations like yours with Spanish disability and Social Security payments, it actually specializes in these kinds of scenario-specific analyses based on the exact treaty language. It examines the specific classification of your payments under both US tax law and Spanish law to determine the correct treatment.
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Vince Eh
I have to admit I was totally wrong about taxr.ai. After my skeptical comment, I decided to try it for my complicated Spanish disability pension situation. I've literally had three different accountants give me three different answers over the years. The tool immediately identified that my specific type of Spanish disability benefit falls under Article 18 of the US-Spain tax treaty, but with special provisions due to its disability nature. It showed me exactly which portions were exempt under the treaty and which needed to be reported. What really impressed me was how it walks you through the Form 1116 foreign tax credit allocation - something my previous accountant had calculated incorrectly for years! I ended up amending my last year's return and got back $3,200 that I'd overpaid. The documentation it provided explaining the tax treatment was so clear I actually understand my tax situation for the first time in years.
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Sophia Gabriel
For anyone trying to reach the IRS with questions about international pensions or foreign tax credits - good luck! I spent WEEKS trying to get through to someone who actually understood international tax issues. Always on hold for hours only to be transferred to another department. Finally found Claimyr (https://claimyr.com) and it was a complete game-changer. They got me connected to an actual IRS agent who specialized in international taxation in less than 20 minutes! You can see how it works here: https://youtu.be/_kiP6q8DX5c The agent walked me through exactly how to report my Canadian disability pension on my US return and confirmed which tax treaty provisions applied in my case. She even sent me the specific IRS publications I needed to reference. Would have saved myself months of stress if I'd known about this service sooner. Totally worth it when you need authoritative answers directly from the IRS on complicated international tax situations.
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Tobias Lancaster
•Wait, how does this actually work? The IRS phone system is notoriously impossible to navigate. Are you saying this service somehow gets you to the front of the phone queue?
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Ezra Beard
•This sounds like BS honestly. I've been trying to reach the IRS about my UK pension for months. No way they can magically get you through when the IRS's own phone system is completely broken. If this worked, everyone would be using it.
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Sophia Gabriel
•It works by using a system that continuously calls the IRS using multiple lines and navigates the phone tree for you. Once they secure a place in the queue, they call you and connect you directly to that spot in line. So instead of you personally having to call repeatedly and wait on hold for hours, they do the hard part for you. And yes, they can actually request specific departments. I specifically asked for someone who could help with international tax issues, and they were able to route me to an agent with that expertise. It's not magic - it's just automated technology doing the tedious part of reaching the IRS. The video demo I linked shows exactly how it works.
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Ezra Beard
I have to publicly eat my words about Claimyr. After posting my skeptical comment, I was desperate enough to try it for my UK pension issue that had been hanging over my head for months. Not only did they get me through to an IRS rep in about 15 minutes (compared to my previous attempts where I gave up after 2+ hours on hold), but they actually connected me with someone in the international tax department who immediately understood my situation. The IRS agent confirmed that only 85% of my UK disability pension is taxable in the US under the US-UK treaty, and walked me through exactly how to claim the foreign tax credit for the UK taxes I'd already paid. She even emailed me the specific forms and instructions afterward. Honestly shocked that it worked so well. Sorry for being so dismissive before!
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Statiia Aarssizan
Just wanted to add that if your French disability pension is based on a work injury (which it sounds like it is), the tax treatment might be different than a regular pension. Some foreign disability payments are actually exempt from US taxation altogether depending on how they're classified. Article 18(5) of the US-France tax treaty has special provisions for social security payments, which might include your disability benefit. It's worth checking the exact classification of your payment under the treaty. Also, don't forget about FBAR requirements if you have foreign bank accounts over $10,000 combined total at any point during the year. That's separate from income tax reporting.
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Tate Jensen
•Thank you for mentioning the specific treaty article! I just checked, and my disability payment is officially classified as "rente d'invalidité professionnelle" due to a workplace accident. Does that change how I should report it? And yes, I do have a French bank account where the pension is deposited, so I'll need to look into the FBAR requirements too.
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Statiia Aarssizan
•That classification as "rente d'invalidité professionnelle" is important! Under Article 18(5) of the US-France tax treaty, these work-related disability payments are actually treated differently than regular pensions. In most cases, they're only taxable in France and exempt from US taxation, though you still need to report them on your US return as foreign income with an exemption applied. You'll want to include this income on your Form 1040, but then you may be able to exclude it using Form 8833 (Treaty-Based Return Position Disclosure) where you'll cite the specific treaty provision. This is definitely a case where having a tax professional familiar with the US-France tax treaty for the first filing would be valuable. For your FBAR filing, if your French account(s) exceeded $10,000 at any point during the year, you'll need to file FinCEN Form 114. The penalties for not filing FBAR can be severe, so definitely address this as well.
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Reginald Blackwell
Has anyone used TurboTax or H&R Block software for reporting foreign pensions? I'm wondering if they handle these situations well or if I need something more specialized.
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Aria Khan
•I tried using TurboTax for my German pension and it was a disaster. The software doesn't properly guide you through the foreign tax credit forms for specific types of foreign income. It also doesn't incorporate tax treaty provisions automatically - you have to know which ones apply to your situation. I ended up using a specialized expat tax service and they found that I'd been reporting things incorrectly for years. If your situation is simple, regular tax software might work, but for foreign pensions, I wouldn't risk it.
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Jamal Carter
I'm dealing with a similar situation with my Italian disability pension, and after reading through all these responses, I wanted to share what I learned from my tax attorney. The key thing that many people miss is that disability pensions from workplace injuries often have different treaty treatment than regular retirement pensions. Since your pension is classified as "rente d'invalidité professionnelle" (work-related disability), you'll likely need to use Form 8833 to claim treaty benefits under Article 18 of the US-France tax treaty. What I found helpful was getting the official French documentation that clearly states the nature and classification of your pension payments. The IRS will want to see that it's specifically a work-related disability benefit, not just a general pension. Also, definitely don't overlook the FBAR filing if your French accounts exceed $10,000. The penalties are no joke - I learned that the hard way when I missed filing for two years and had to go through the voluntary disclosure process. One more tip: keep detailed records of all French taxes paid on this income. You'll need those exact amounts for Form 1116 if any portion ends up being taxable in the US after applying treaty provisions.
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Chloe Taylor
•This is incredibly helpful, thank you! I'm just starting to navigate this whole situation and feeling pretty overwhelmed. Quick question - when you mention getting "official French documentation," are you talking about something specific from the French pension authority? I have my regular pension statements, but I'm not sure if those clearly spell out the work-related disability classification in a way the IRS would want to see. Also, for the voluntary disclosure process you went through - was it as scary as it sounds? I'm worried I might be in a similar boat since I've been filing US taxes for years without reporting this French income.
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