France can tax an American's retirement income at zero. It can also be one of the least forgiving countries in the world to die in. Both are true, and most families only learn the second half after they've already moved.
Vincent Berthier de Bortoli, a French tax attorney and STEP member whose clients are now almost entirely American, joins the podcast to explain how the US-France tax treaty actually works, why France has no legal concept of an "estate," and why a US trust can quietly turn a 0 percent tax situation into a 31.4 percent one.
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CHAPTER TIMESTAMPS
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00:00 - Why Americans are moving to France right now
02:35 - Inside the US-France tax treaty: pensions, IRAs, and Roth accounts taxed at zero
07:31 - Why dying in France is never a good idea, tax-wise
10:22 - Inheriting from a US parent while living in France, and the six-year tax holiday
13:47 - The one-euro filing rule most Americans don't know about
17:56 - Why French tax authorities almost always come after a US trust
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ABOUT THE GUEST
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Vincent Berthier de Bortoli is a French tax attorney and STEP member based in the French Alps. He has practiced tax for nearly a decade, founded his own French tax practice in October 2023, and now advises a clientele that is roughly 90 percent American families relocating to France. He also is a member of the Passport To Wealth® community.
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ABOUT YOUR HOST
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Arielle Tucker, CFP® & IRS Enrolled Agent with Connected Financial Planning, is a cross-border financial planner based in Switzerland helping Americans living abroad navigate U.S. taxes, international investments, and cross-border financial planning.
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LOVE THIS EPISODE?
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Follow the show and leave a rating on Apple Podcasts or Spotify, it's the single biggest thing you can do to help other cross-border families find this show.
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ABOUT PASSPORT TO WEALTH®
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Passport To Wealth® is the platform for current and aspiring US expats. We connect globally mobile Americans with vetted, licensed cross-border financial advisors, tax professionals, and relocation experts who understand the financial and legal complexities of life abroad.
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LINKS & RESOURCES
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Website: https://www.passporttowealth.com
Instagram: https://www.instagram.com/passporttowealthofficial
LinkedIn: https://www.linkedin.com/company/passport-to-wealth
VBDB Website: https://www.vbdbtax.com/en/international-tax-attorney
Vincent's LinkedIn: https://www.linkedin.com/in/vincentbdb
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This episode is for educational purposes only and does not constitute tax, legal, or financial advice. Individual circumstances vary. Consult a qualified cross-border financial professional before making any financial or tax decisions.
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