France near Switzerland (relatively anyway; the border doesn’t have to be walking distance) is near the top of our list when my wife finally pulls the plug in a couple years (I’m a citizen of a different EU country as well as the US; my wife is an American). However, one reason—besides language—France has been more attractive than Germany or even Switzerland is our understanding of how the US-France tax treaty deals with pension income (I realize people can have significant pension income from other countries, and it might be taxed very differently in France, so this is just about our situation, which might be relatively common). We’re not lawyers, especially not international tax lawyers, but the language of the treaty seems pretty straightforward. From the 2004 amendments:
ARTICLE III
Article 18 (Pensions) of the Convention shall be deleted and replaced by the following:
“ARTICLE 18 - Pensions
Payments under the social security legislation or similar legislation of a Contracting State to a resident of the other Contracting State, and pension distributions and other similar remuneration arising in one of the Contracting States in consideration of past employment paid to a resident of the other contracting State, whether paid periodically or in a lump sum, shall be taxable only in the first-mentioned State. For purposes of this paragraph, pension distributions and other similar remuneration shall be deemed to arise in a Contracting State only if paid by a pension or other retirement arrangement established in that State.
This seems to say that pensions are only taxed by the source state, meaning for us, by the US (which would oF course tax them anyway), and are not taxed by France. Maybe we’re reading this wrong and also need to look elsewhere?