Franco-American inheritance planning presents a complex web of conflicting tax systems and legal principles that can significantly impact expatriates' legacies without proper planning.

• French inheritance tax focuses on beneficiaries, with tax rates varying dramatically based on relationship (0% for spouses, up to 60% for unrelated beneficiaries)
• US maintains citizenship-based taxation, claiming worldwide assets regardless of residency
• French forced heirship rules legally reserve portions of estates for children, limiting testamentary freedom
• The 1978 France-US Estate Tax Treaty creates complex rules determining which country has primary taxing rights
• Notaires in France and executors in the US must coordinate to file proper documentation in both countries
• Strategic lifetime gifting can utilize the €100,000 tax-free allowance that renews every 15 years
• Assurance Vie (French life insurance) provides exceptional benefits, operating outside forced heirship rules
• US trusts often create complications in France, potentially triggering punitive tax treatment
• Effective planning requires a "bilingual strategy" addressing both systems holistically
• Professional guidance with Franco-American expertise is essential for navigating this complex landscape

What assumption might you hold about your estate planning, based on US principles, that needs reevaluation given France's fundamentally different approach?

Read French Inheritance tax for U.S. Citizens Resident in France for more information.

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