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Discussion Starter · #1 ·

My wife and I are moving to France. I'm Irish and Kelly is American.

I know there is an agreement between the US and the EU about income tax but I'm not sure what the forms are.

In Ireland you fill out an E101 certificate/A1 Portable document which states that you are paying tax in the country you came from and will not be paying tax in the country you will be residing, in for the duration of a project.

Is there and equivalent form here in the U.S.? I will be paying tax in the U.S. and do not want to get caught paying into the French system.

Can anyone advise?

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No, there isn't a form like that for France. France (like the US) requires you to declare your worldwide income - including amounts you make in the US. (Just as the US requires you to declare you worldwide income if you're filing as a resident - or in your case, filing jointly with your American wife.)

In France, there is a second form that you fill out as part of your tax declaration (a 2047) where you detail all your foreign sources of income according to their classification for French tax purposes. For overseas earned income, it's most likely that your earnings will fall into the category where they are taken into consideration for calculating your French tax rate, but then you are granted a credit (at French tax rates) for any tax generated by those amounts.

But if you are going to be residing in France while earning money in the US, why would you pay taxes to the US? (Especially if you're not a US citizen?) Normally, you are deemed to be working in the country where you are physically located while doing the work. I would think you would pay French taxes and take advantage of the US FEIE (Foreign Earned Income Exclusion) or simply take the French taxes you pay against any US tax obligation.

Be careful with this arrangement. It can backfire and may wind up being simply convenient for the employer without consideration for the problems it can create for you.
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