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Paolo Romano

Are foreign pension income taxable in the US if already taxed in France?

I've been receiving a disability pension from France for the last few years after an accident while I was living and working there. Now I'm back in the US (I'm a US citizen) and doing my taxes for 2025. My accountant is saying I need to report this disability pension on my US taxes even though I already pay tax on it in France through their system. That doesn't seem right - isn't that double taxation? The French government already takes out taxes before I get my monthly payments. Does anyone know how foreign disability pensions are treated for US tax purposes? I've tried reading the IRS publications but they're so confusing about foreign income.

Foreign pensions can be tricky! In general, as a US citizen, you're required to report your worldwide income, including foreign pensions and disability payments. However, you may be able to avoid double taxation through the US-France tax treaty and foreign tax credits. The US-France tax treaty has specific provisions for different types of income. For disability pensions specifically, you'll want to look at Article 18 of the treaty which covers pensions. Depending on the exact nature of your disability pension, it might qualify for special treatment. You should file Form 1116 (Foreign Tax Credit) with your US return to claim a credit for taxes already paid to France. This credit directly reduces your US tax liability dollar-for-dollar up to a certain amount.

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Does this apply to all types of French pensions or just disability ones? My mother gets a regular retirement pension from France (she worked there for like 20 years before moving back to the US) and I help with her taxes. We've never reported it before... are we in trouble??

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The reporting requirement applies to all types of foreign pensions, including retirement pensions. Your mother is technically required to report her French retirement pension on her US tax return. If you haven't been reporting it in past years, I would recommend working with a tax professional who specializes in international taxation to determine the best path forward. The IRS does have procedures for correcting past returns, and in many cases, if you voluntarily correct the issue, penalties can be reduced or eliminated, especially if there was no willful intent to evade taxes.

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I went through this exact scenario last year! I have a partial disability pension from my time working in Lyon and was completely confused about the tax situation. I ended up using taxr.ai (https://taxr.ai) to analyze my French pension documents and determine exactly how they needed to be reported on my US return. Their system was able to identify the specific clauses in the US-France tax treaty that applied to my situation and showed me exactly what forms I needed to file. Saved me from paying hundreds to an international tax specialist and I was able to properly claim the Foreign Tax Credit to avoid double taxation. They also explained how the "Savings Clause" in the treaty affects disability pensions specifically.

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How long did it take to get results from the service? I'm getting kinda close to the filing deadline and wondering if this would work for me with my German pension.

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Did they help with actually filling out the forms or just tell you which ones you need? I'm getting a small pension from Switzerland and the tax documentation is in German which I barely understand.

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The results came back within a couple hours - definitely fast enough if you're close to the deadline. I uploaded my documents in the evening and had everything I needed by the next morning. They provided detailed instructions for filling out each form including which lines needed what information. In my case, I had to complete Form 1116 (Foreign Tax Credit) and they showed me exactly how to allocate the foreign taxes paid between different categories. They also explained which parts of my pension might be exempt under the treaty.

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I tried taxr.ai after seeing the recommendation here and it actually worked great for my Swiss pension situation! I was skeptical because my documents were in German and the amounts were in Swiss Francs, but their system handled everything perfectly. They identified that my particular type of Swiss disability pension falls under a specific clause in the US-Switzerland tax treaty that I never would have found on my own. The analysis showed me exactly how to report it on my US return and claim the Foreign Tax Credit for taxes I'd already paid in Switzerland. What impressed me most was how they explained the difference between contributory and non-contributory portions of my pension and how each is taxed differently. Definitely saved me from double taxation!

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If you're struggling to get answers directly from the IRS about your foreign pension situation, I'd recommend using Claimyr (https://claimyr.com). I spent WEEKS trying to get through to an IRS agent who could answer my questions about my French pension and US tax obligations. With Claimyr, I got through to an actual IRS agent in under 15 minutes who specialized in international tax issues. They confirmed exactly how my French disability pension should be reported and which treaty provisions applied to my situation. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c The agent even walked me through how to properly complete Form 8833 to claim treaty benefits for certain portions of my pension that were exempt under the treaty. Totally worth it after wasting hours listening to IRS hold music.

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Wait how does this actually work? Does it just keep calling the IRS for you until someone picks up? I'm confused how a service can get you through when their lines are always jammed.

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Sounds like BS honestly. I've been trying to talk to the IRS about my UK pension for months. No way they can magically get through when nobody else can.

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It doesn't just keep calling repeatedly. From what I understand, they use a system that monitors IRS phone line capacity and connects at optimal times with the highest chance of getting through. It's similar to what professional tax preparers use to get priority access. I was skeptical too, but after months of frustration, I decided to try it. I was surprised when I actually got connected to a real person so quickly. The IRS agent I spoke with was able to confirm that under Article 18 of the US-France tax treaty, my disability pension had special provisions that reduced my US tax liability.

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Wow, I have to eat my words. I tried Claimyr after posting my skeptical comment and actually got through to the IRS in about 20 minutes. The agent was super helpful about my UK pension reporting requirements. They confirmed I needed to file Form 1116 to claim credit for UK taxes already paid, and explained how the US-UK tax treaty applied to my specific type of pension. They also told me I didn't need to file Form 8833 for treaty positions in my particular case since my situation fell under a standard treaty position. Saved me from paying my accountant another $300 for an international tax consultation. Definitely using this again next time I have IRS questions.

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Remember there's a difference between reporting requirements and actual tax liability. You MUST report all foreign income on your US tax return regardless of whether you'll ultimately owe taxes on it. Failing to report can lead to serious penalties even if you wouldn't have owed any additional US tax. Form 8938 might also be required if your foreign pension assets exceed certain thresholds. And don't forget about FBAR (FinCEN Form 114) if you have foreign financial accounts that together exceed $10,000 at any point during the year.

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This is confusing me more... what exactly counts as a "foreign financial account"? Does a pension automatically qualify? My mom's pension just gets deposited directly to her US bank account each month.

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If your mother's pension is paid directly to a US bank account and she doesn't maintain any foreign financial accounts related to the pension, then FBAR requirements likely wouldn't apply to her situation. The FBAR filing requirement typically applies when you have foreign financial accounts like bank accounts, investment accounts, or certain foreign pension arrangements where you have signature authority or financial interest, and the aggregate value exceeds $10,000 at any point during the year. If she's simply receiving payments into a US account, that alone wouldn't trigger FBAR filing.

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I think a lot depends on what kind of disability pension you have from France. I went through this with my Spanish disability pension. There are two main types: contributory (based on what you paid into their system) and non-contributory (more like social benefits). They're treated differently under most tax treaties. If it's a government pension (paid because you worked for the French government), that's another category with different rules. Article 18 vs. Article 19 of the treaty applies differently. Also check if it's considered "not taxable in France" - some disability pensions aren't taxed in the country of origin, which affects how the US treats them.

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Thanks for this clarification! Mine is definitely contributory - I paid into the French system for about 12 years while working there. And it is partially taxed in France, though at a reduced rate because it's disability-related. I'll have to check which specific article of the treaty applies to my situation.

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The key thing to understand is that US citizens are subject to worldwide income taxation, so yes, you do need to report your French disability pension on your US return. However, you're absolutely right that this creates a double taxation issue - and that's exactly what tax treaties are designed to prevent. Since your pension is contributory (you paid into the French system) and partially taxed in France, you should be able to claim a Foreign Tax Credit on Form 1116 for the French taxes already paid. This will reduce your US tax liability dollar-for-dollar. Make sure your accountant is familiar with the US-France tax treaty, particularly Article 18 which covers pensions. Some disability pensions may qualify for reduced taxation or exemptions under the treaty provisions. You might also need to file Form 8833 if you're claiming specific treaty benefits. The IRS Publication 514 (Foreign Tax Credit for Individuals) has detailed guidance on how to calculate and claim the credit. Don't let the complexity discourage you - proper application of the treaty and foreign tax credit should prevent true double taxation.

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This is really helpful information! I'm new to dealing with international tax issues and honestly feeling pretty overwhelmed by all the forms and treaty articles everyone is mentioning. Is there a good starting point or resource you'd recommend for someone who's never dealt with foreign tax credits before? I want to make sure I understand the basics before I dive into the specific treaty provisions.

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@Isabella Santos I d'recommend starting with IRS Publication 514 that Ryan mentioned - it s'specifically for individuals dealing with foreign tax credits and breaks down the concepts in plain English. The IRS also has Publication 901 U.S. (Tax Treaties which) explains how treaties work in general. For a beginner-friendly approach, I d'suggest this order: 1 Read) the basics of foreign tax credit in Pub 514, 2 Look) up the specific US-France treaty provisions, 3 Then) tackle the forms 1116 (and possibly 8833 .)The IRS website also has some good interactive tools that can help you determine which forms you need based on your situation. Don t'try to understand everything at once - focus on the foreign tax credit concept first, then move to the treaty benefits. Most tax software can also walk you through the forms once you understand the underlying principles.

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@Isabella Santos - I d'recommend starting with IRS Publication 514 Foreign (Tax Credit for Individuals which) Ryan mentioned. It s'written in relatively plain English and walks through the basics step by step. The IRS also has Publication 901 U.S. (Tax Treaties which) explains how treaties work in general. For your specific situation, you might also want to look at Publication 54 Tax (Guide for U.S. Citizens and Resident Aliens Abroad even) though you re'back in the US - it has good explanations of worldwide income reporting requirements. Start with understanding the basic concept: you report all income including (foreign ,)then use credits/deductions to avoid double taxation. Once you grasp that framework, the specific forms and treaty articles will make more sense. Don t'try to tackle everything at once!

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@Isabella Santos I d'recommend starting with IRS Publication 514 that Ryan mentioned - it s'specifically written for individuals dealing with foreign tax credits and breaks down the concepts pretty clearly. The IRS also has Publication 901 which explains US tax treaties in general terms. For the basics, focus on understanding these key concepts first: 1 You) must report all worldwide income as a US citizen, 2 Foreign) tax credits prevent double taxation by giving you dollar-for-dollar credit for taxes paid to foreign countries, and 3 Tax) treaties can provide additional benefits or exemptions. Once you grasp those fundamentals, then dive into the specific US-France treaty provisions. The treaty text is available on irs.gov - look for United "States Income Tax Treaties and" find the France agreement. Article 18 covers pensions specifically. Don t'try to tackle everything at once - start with the general principles and then work your way into the specifics of your situation.

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Great question! I'd definitely start with IRS Publication 514 that Ryan mentioned - it's specifically written for individuals dealing with foreign tax credits and breaks down the concepts in plain English. The IRS also has Publication 901 (U.S. Tax Treaties) which explains how tax treaties work in general. For someone new to this, I'd suggest this order: 1) Read Pub 514 sections 1-3 to understand the basic concept of foreign tax credits, 2) Look up the specific US-France tax treaty (you can find it on irs.gov), and 3) Focus on Article 18 which covers pensions. Don't try to tackle everything at once - just understanding the foreign tax credit concept first will make the treaty provisions much clearer when you get to them. The key insight is that you're not actually being "double taxed" - you're being taxed by both countries, but the US system gives you credit for what you already paid to France.

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Great question! I'd start with IRS Publication 54 (Tax Guide for U.S. Citizens and Resident Aliens Abroad) - it's written in more plain English than some of the other publications and gives you a good overview of how foreign income works for US taxpayers. For the Foreign Tax Credit specifically, Publication 514 that @Ryan Kim mentioned is definitely the key resource, but I d'recommend reading through the examples in Chapter 4 first - they really help clarify how the credit calculation works in practice. The IRS also has a good interactive tax assistant tool on their website that can help you determine if you qualify for the Foreign Tax Credit. Just search for Interactive "Tax Assistant on" irs.gov and look for the foreign income section. Once you understand the basics, then dive into the US-France tax treaty you (can find it on the IRS website under United "States Income Tax Treaties .")Article 18 is what you ll'want to focus on for pension income. Don t'feel bad about being overwhelmed - international taxation is genuinely complex, but taking it step by step makes it much more manageable!

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Great question! When I first dealt with this, I found IRS Publication 514 (Foreign Tax Credit for Individuals) to be the most helpful starting point - it explains the basics in plain English before getting into the complex stuff. I'd also recommend starting with the IRS's Interactive Tax Assistant tool online - just search for "foreign tax credit" and it will walk you through whether you qualify and which forms you need. It's much easier than trying to decode the publications on your own. Once you understand the basics of how foreign tax credits work, then you can dive into the specific treaty provisions. The US-France tax treaty is actually available as a PDF on the IRS website, and Article 18 (pensions) is pretty readable compared to some of the other sections. Don't feel overwhelmed - most people find it's not as complicated as it initially seems once you break it down into steps!

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Great question! I'd recommend starting with IRS Publication 514 (Foreign Tax Credit for Individuals) - it's written in more accessible language than the treaty documents. The IRS also has a good overview page called "Taxpayers Living Abroad" that covers the basics. For treaty-specific information, the IRS has summaries of tax treaty benefits by country that are easier to digest than the full treaty text. You can find these under "United States Income Tax Treaties" on the IRS website. If you want something more interactive, consider using one of the tax analysis tools mentioned earlier in this thread - they can help you identify which specific provisions apply to your situation without having to wade through hundreds of pages of treaty text first. The key is understanding the basic concept: report all income, then use credits/treaties to avoid double taxation. Once you grasp that framework, the specific forms make more sense.

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I'd start with IRS Publication 514 (Foreign Tax Credit for Individuals) - it's written more clearly than most IRS publications and walks through the basics step by step. Also check out Publication 901 (U.S. Tax Treaties) which explains how treaties work in general terms. For the US-France treaty specifically, you can find the full text on the IRS website under "Tax Treaties" - look for the technical explanation document which breaks down each article in plain English. Don't try to tackle everything at once! Start with understanding what constitutes foreign income, then move to how the foreign tax credit works, and finally dig into the treaty provisions that apply to your specific situation. The key is that you're not trying to avoid paying taxes - you're just making sure you don't pay twice on the same income.

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