French Civil and Tax Law and U.S. Estate Planning

In today’s world, many families maintain ties across borders, and some of the most complex planning challenges arise when those borders are between the United States and France. Whether through dual citizenship, inheritance, cross-border marriages, U.S.-based investments or a beloved French château, more families now find themselves navigating the intersection of two very different legal and tax systems.

From an estate-planning perspective, these families share familiar goals: smooth transfer of assets and minimizing taxes, preferably in both countries. Yet even the most basic assumptions from a U.S. standpoint, such as testamentary freedom or using revocable trusts to avoid probate, may not hold true under French law. At the same time, f…