French Taxes, multiple overseas income

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French Taxes, multiple overseas income


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Old 12th June 2019, 12:48 PM
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Default French Taxes, multiple overseas income

Greetings,

I am looking for some advise regarding our tax declaration in France.

My wife and I are dual citizens (USA, Netherlands) and have moved to Montpellier France Jan 1, 2019. My wife does not receive an income from any source.

My situation, however, is different. I continue to be employed (part-time) at a University in Illinois, receive a pension from the Illinois State Government, and have a part-time job in Germany.

The foreign jobs are performed in the US and Germany on irregular visits, but are paid out monthly. My US University income is reduced by maximum contributions to a 403b and a 457 deferred pension plan; what remains is taxed by the state (IL) and federal. The pension is taxed at the Federal level, but not the state level. My german income is taxed in germany; I pay income tax, but also health care premiums and retirement pension premiums, etc, even though I do not think I am eligible for health care.

We have both purchased private health insurance for 2019 and recently received our carte de sejours.

So, here is my question :

I understand the pension is not taxed in France by treaty. What about the other US income; in the end it will be around $6,000 because the rest is deferred into pension fund contribution. What about the german income?

An finally, what about joining the french health care system. I understand there is a % charge, fair enough & I agree, but over what amount would the % be?

I feel I may need to hire a tax expert, at least the first time. Any recommendations?

I have posted similar questions in the past before moving to France, but now that we are here, its becoming more "urgent" and I like to get my ducks in a row so to speak ..

we love France, best decision ever ...

Greetings, and thanks,

Pieter

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Old 12th June 2019, 01:08 PM
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Oh dear, this IS something of a complicated situation.

If the US job is performed exclusively in the US, then you are probably liable for the US taxes (including US Social Security) - but you report the income also on your French tax declaration (as foreign source income). You won't be taxed on it by the French as long as you are actually doing the work in the US.

I believe the same is true for your German income (again, as long as you do all the work when you are physically present in Germany, and not "telecommuting").

I wonder a bit about the state tax on your US income, as you aren't actually resident in the state (other than maybe for the time you are there doing the work). I suspect the university may not be able to handle things any other way (especially if it is one of the state universities). But you may want to ask about reclaiming any state tax they are withholding based on your non-resident (in the state) status.

If you are paying for German health insurance, you may want to ask in Germany if there is any way you can get some sort of certificate stating that you are covered by the German health system (similar to the S1 you hear so much about the Brits having from their home country). That might allow you to join the French health care system and have the Germans pay for it. (But possibly not.)

Otherwise, you apply to CPAM once you have 3 months of verifiable residence in France. Ultimately you'll be billed based on what you declare on your French tax declarations for 2019, with some consideration of your "foreign source" income. Or, perhaps they will consider the pension from the US university sufficient for you to have health care coverage. Your best bet is to make an appointment and ask the local CPAM office.

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Old 12th June 2019, 01:17 PM
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Default IL tax

Thanks Bev,

You are extremely helpful, as always ...

Yes, the work is performed in Germany and the US ... when I travel there ..

I have a company file my taxes in the US (its called greenback, btw, good service for not too much of a fee) .. I understand I have to pay the IL tax because the work is done in IL ... since I contribute most of the salary to a 403b&457, and the IL tax is 3% is really not that much ...

I will see whether I can get a statement from Germany re: health care; we will see ... we so need to go to the CPAM office soon .. do we need an appointment? prob also should bring a French native speaker for that .. what docs do you need at CPAM .. only the carte de sejours and passport?

Can you or anybody recommend a tax accountant, or do you think we can do it our self ?

Thanks & best,

Pieter

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Old 12th June 2019, 01:25 PM
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Complicated.
The two queries that came into my head are:
What about CSG on foreign earned income
and
Normally if you are working and paying social security in one EU state and living in another EU state, you are classed as a frontalier and the state where you work, covers your healthcare in the state where you live, via a workers S1 form. This is an EU document not a British invention - https://europa.eu/youreurope/citizen...s/index_en.htm. As far as I am aware the fact you also work in the US shouldn't change this but you would need to ask Germany. I suspect that even if they say No, CPAM would want to see this in writing before they would consider an application to join PUMA.

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Old 12th June 2019, 02:10 PM
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Default German Health Care

Had a look again at the german withholdings on my salary there. I misinterpreted the year end statement .. I actually do not pay into the german health care system at all, on the year end statement there is some sort of "credit" statement, I guess for being ensured elsewhere (which I was, first in the UK, not private health) .. we lived in the UK for 2 years but left prematurely to France as we always planned in the end (due to brexit ;-} ). I took that for healthcare premium, but my monthly pay stubs don't show that.

So thankfully, that "complication" does not exist after all ...

P.

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Old 12th June 2019, 02:14 PM
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For the health cover in France when you are working in Germany and paying health contributions on your salary in Germany then you should ask the body that runs the health care in Germany for the S1 form which you will need to take to CPAM as ET has said

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Old 12th June 2019, 04:49 PM
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One small caveat here - if you aren't paying into the German system for health care, then CPAM may insist on seeing some proof that you have health insurance cover here in France for the "interim period" (i.e. during the period you are establishing your residence here in France).

Best thing might be to contact CPAM in your area (or have a French speaking friend do so for you) to ask what documents are required to sign up with CPAM, and whether or not an appointment is needed (and if so, how to make the appointment - by phone or online). As an EU national "exercising your rights of movement" they will very often require you to have health care insurance (usually through a private policy) for the first 6 to 12 months in France. (Technically 3 months, but given the waiting time for processing your registration it's probably safest to prolong that a bit.)

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Old 12th June 2019, 04:50 PM
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Quote:
Originally Posted by pdetombe View Post
Had a look again at the german withholdings on my salary there. I misinterpreted the year end statement .. I actually do not pay into the german health care system at all, on the year end statement there is some sort of "credit" statement, I guess for being ensured elsewhere (which I was, first in the UK, not private health) .. we lived in the UK for 2 years but left prematurely to France as we always planned in the end (due to brexit ;-} ). I took that for healthcare premium, but my monthly pay stubs don't show that.

So thankfully, that "complication" does not exist after all ...

P.
I suspect it might be less complicated if you were paying contributions in Germany. Working in the EU and not paying contributions into/not being covered by any EU social security system, is an irregular situation to be in. The EU has a pretty joined-up social security coordination policy that sets out where contributions are to be paid in what circumstances, to ensure that everyone who lives and works in the EU has continuous cover, but it sounds as if you have somehow fallen through a gap.
For the general principle https://ec.europa.eu/social/main.jsp...=849&langId=en
and for the rules https://ec.europa.eu/social/main.jsp...=851&langId=en - but, I don't know whether the fact you also work in the US would complicate things.

Does Germany know that you are no longer covered by the UK system (if that is the case)?


Last edited by EuroTrash; 12th June 2019 at 05:00 PM.
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Old 12th June 2019, 05:03 PM
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Quote:
Originally Posted by EuroTrash View Post
I suspect it would be less complicated if you were paying contributions in Germany. Working in the EU and not paying contributions into/not being covered by any EU social security system, is an irregular situation to be in. The EU has a pretty joined-up social security coordination policy that sets out where contributions are to be paid in what circumstances, to ensure that everyone who lives and works in the EU has continuous cover, but it sounds as if you have somehow fallen through a gap.
Does Germany know that you are no longer covered by the UK system (if that is the case)?

If your status is worker, ie you have a regular and significant earned income, you can't simply apply to join CPAM as if you were inactif or retired.
The thing is that Germany's health care system is kind of based on sort of semi-private insurers rather than a single "national" system. And if someone isn't resident in Germany, but only working there part-time I'm not sure how that would be handled.

There is also the matter of receiving a pension from the US. That may actually provide entry into the CPAM system.

It's one of those questions that does not fit the pigeon holes - and generally the best approach is to come forward and let the "experts" at CPAM figure out what the situation (or rather the "statut") is that applies. It's going to take a LONG time to figure it out, no matter what.

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Old 12th June 2019, 05:11 PM
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Quote:
Originally Posted by Bevdeforges View Post
The thing is that Germany's health care system is kind of based on sort of semi-private insurers rather than a single "national" system. And if someone isn't resident in Germany, but only working there part-time I'm not sure how that would be handled.

There is also the matter of receiving a pension from the US. That may actually provide entry into the CPAM system.

It's one of those questions that does not fit the pigeon holes - and generally the best approach is to come forward and let the "experts" at CPAM figure out what the situation (or rather the "statut") is that applies. It's going to take a LONG time to figure it out, no matter what.
Sorry Bev, I read my own link and changed my post since you quoted it
It might be a question for Solvit, the EU citizens advice service - they're very good and very quick to reply.
I suspect that France, with its focus on workers rights, would insist that anyone who is employed, even part time, needs more social cover than just healthcare - sick pay entitlement,employment protection.
A conundrum indeed.

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