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IRAs - Pensions per Article 18 of tax treaty?

22 years ago
For a permanent U.S. resident of France, does Article 18, Paragraph 1a include IRAs in this definition: "except as provided in subparagraph (b), pensions and other similar remuneration, including distributions from pension and other retirement arrangements, derived and beneficially owned by a resident of a Contracting State in consideration of past employment, whether paid periodically or in a lump sum, shall be taxable only in that State"?

If not, will conversion of IRAs to Annuities accomplish the exclusion from French taxation?

Thanks...Gary

French Riviera House Hunting - FRH
French Riviera House Hunting - FRH
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French Riviera House Hunting - FRH
French Riviera House Hunting - FRH

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