My wife started receiving a small pension from France last year, and it's not clear if/how to report it on our IRS return. We are US residents and she is dual US and French citizen. We use TurboTax to file our tax return.

The pension has two components: a state pension (equivalent to US Social Security benefits) and an additional private pension.

Apparently, such pensions are covered by a treaty between US and France that dictates what and where is reported and taxed. For example, it appears that a French state pension is reported and taxed in France. I'm not sure about a private French pension.

I talked to a TurboTax expert who said in general foreign pensions are reported on a substitute form 1099R, but she could not comment on how this treaty affects that, if at all.

So my questions is how and in which country (maybe both) do we report these pensions.

Help will be appreciated.

Thank you

  • 1
    Find a CPA who is specialized in expat tax. The private pension may be a PFIC and subject to complex and special rules.
    – xuhdev
    Commented May 30 at 18:41

1 Answer 1


Asking Intiut/HRBlock "experts" for anything not immediately trivial is pointless. You need a tax professional who's familiar with the dual taxation and the Franco-American treaty. You best chance is to find someone handling US expats in France, or someone who's proficient in handling expats in the US.

State pensions, Social Security, and private pensions are all different things and are covered by different treaty provisions. Even if you're claiming a treaty benefit, you still need to report the income and then back it out with a form 8833 attached.

Once you have a professional do it for the first time you can probably copy forward for the following years. But it doesn't sound like a DIY thing to set up unless you really know what you're doing.

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