Inheritance & Succession in France

How French Succession Law Affects U.S. Owners and Heirs

A second home or other assets in France can bring part of your estate under French law, even if you live in the United States. France applies the EU Succession Regulation, under which the law of a person's habitual residence generally governs the succession unless that person has chosen the law of their nationality. Because French law has a strong forced-heirship tradition (réserve héréditaire), the choice of law can matter a great deal. A French succession usually runs through a French notary (notaire), and French inheritance tax (droits de succession) may apply to assets located in France.

Our French Inheritance and Succession Services

• Advice on the French forced-heirship system, the reserved portion and the rights of foreign-domiciled testators.
• Drafting bilingual wills that satisfy French formalities and coordinate with your U.S. estate plan.
• Managing French inheritance tax (droits de succession) obligations and reviewing treaty-based relief.
• Working with French notaires on estates involving U.S. citizens, French residents and non-residents.

Frequently Asked Questions About Property and Inheritance in France

Which country's law applies to my French property?

That depends on where you live and whether you have chosen the law that will govern your estate. Under the EU Succession Regulation the default is generally the law of your habitual residence at death, but you can often choose the law of your nationality. We review your situation and explain your options.

What is the réserve héréditaire?

It is the part of an estate that French law reserves for a person's children and, in some cases, a surviving spouse. Whether it applies to your estate depends on which law governs your succession, so choosing and documenting the applicable law is an important planning step.

Do I need a French will in addition to my U.S. will?

Many owners of French property find it useful to have a will that works in France and is coordinated with their U.S. documents, so the two do not conflict. Whether you need one depends on your assets and your family.

Related Resources

• International estates and inheritance
• Cross-border inheritance planning: choosing the right law for your estate
• Other country guides: Spain, Portugal, Italy and Germany

Contact us today for a free initial consultation on your European estate or cross-border succession matter. Our bilingual team and international network help ensure a smooth transition for your estate across the U.S. and Europe.

This page is general information, not legal advice. Foreign law changes, and every estate is different.