It just gets better!
I sort of follow it, but would like someone like George 1 to put it into everyday english… but does seem that instead of paying a further 15% tax in France, much the same as one with a UK CG liability, a US person resident in France gets a credit 
I just wonder if this treaty was drawn up after a long lunch where the red was flowing well…
On capital gains, a US Citizen (not a person) gets relief on capital gains derived from purely US sources. Investments, not real estate. This still counts towards CSM, afaik. I haven’t had any.
To add a bit of perspective to those who are following the health care part of the crisis in the US, almost all of the current issue does not really affect Americans of Medicare (65) age. Their premiums are going up slightly, but overall, traditional Medicare is pretty good and not terribly expensive relative to US costs. The average person on Medicare with a solid doctor (Part B) and drug (part D) plan might pay something like $5k year and be really fully covered. It is the people slightly younger who may not be covered by employer plans that are getting abused via Obamacare. Unfortunately, the fact that a significant number of Americans are covered through work really disguises the extent of the iceberg/problem because their employer eats a significant amount of the cost and they don’t see the full impact until they lose their jobs or try to retire early. Of course, they really are paying for it as their salaries are being reduced by the invisible amount their employer is shelling out; All in the name of freedom. Stupid country can’t even handle the metric system.
Flattering, but the US/France treaty is unfortunately incapable of being put into everyday English, in my view. It is enormously complex, and that is reflected in the various guides and commentaries on that treaty, which are very far from being easy to follow. The US treaty negotiators did their job properly, namely of protecting US citizens from genuine double taxing scenarios, which is one of the primary aims of any treaty.
IMO, it is the only thing Warren Christopher ever got right. Was it the red wine at lunch?
I wonder if this is being slightly unfair to WC! Didn’t he play a key role in negotiating the release of the US hostages held in Iran, during the Carter Administration? I believe he was also closely involved (albeit behind the scenes) in the Oslo Accords between Israel and the Palestinians. I would defer to your much greater knowledge of how things work in the US government, but I also wonder, as Secretary of State, whether he would have had much of a role in the US France tax treaty negotiations? Wouldn’t that normally have been the remit of Treasury, rather than State, absent any particular diplomatic issues? I liked his unfashionable preference for modesty, and avoiding self-publicity, unlike for example his contemporaries such as Richard Holbrook…
I am probably being very unfair to WC. I can’t say I really ever paid much attention to his career. You are right that he was pretty low key. I doubt that he had much to do with the treaty other than sign it. It wouldn’t surprise me if John Kerry had gotten involved, but the treaty was in effect by the time he was SoS.
Hello, just seeing this thread. For what it’s worth, I’m American and have been here 12 years. Was a micro-entrepreneur here until 2023, then retired, and have a small French pension.
I drew my US Social Security retirement early at 62–10 years ago. At that time, I received assistance from Impots on my tax filing. My SS income is deemed a state pension and not taxable.
I don’t have any passive income, just retirement income. If I had passive income of more than €23k I would need to pay PUMA tax. My US SS retirement is exempt from PUMA. Also, since I have French retirement income, it is also exempt from PUMA.
Note: PUMA tax is imposed on French fiscal residents whether they participate in the French healthcare system or not (even those with just private health ins)
I have certainly read in legal literature that having private insurance does not qualify a person for exemption from the CSM/PUMA tax. In practice though I’ve never come across anyone with full private insurance who was actually charged the PUMA tax.
There is a well known case about this, and the people (American) were forced to pay several years of back charges. I’ll see if I can find it.
We paid when we first arrived as early retirees without private insurance. It wasn’t called CSM then but something else. And we reckoned very good value!
Yes, I remember that case law. This might be it:
https://www.courdecassation.fr/decision/685f7c05bc30e19b8e5f1cd0
The court held that the lady had to pay the PUMA tax arrears. And that URSSAF didn’t have to reimburse her for the private insurance premiums.
The CSM replaced the CMU.
I agree it’s very good value.