US 409A Deferred Compensation & French Tax Residency

Offshore Tax with HTJ.tax · Feb 28, 2026 · 1m

Cross-border executives often assume deferred compensation is taxed where it was earned. Under U.S. Section 409A, that assumption can be costly once you become French tax resident.In this episode, we unpack how Section 409A deferred compensation is taxed when the recipient is resident in France—and how double taxation is relieved under the treaty framework.🇫🇷 French Tax Treatment: Taxed on ReceiptFrance taxes its residents on worldwide income.When 409A deferred compensation is paid:• It is generally treated as employment income • It is taxable in France in the year of receipt • It is included…