Cross-Border Private Client Services

French and U.S. Cross-Border Inheritance Lawyer for International Individuals

Atlantic Bridge advises U.S. and international families on cross-border inheritance matters between France and the United States—structuring succession, navigating conflicting legal systems, and ensuring the smooth transfer of assets across jurisdictions.

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The requirements

Core Considerations for Cross-Border Inheritance

Applicable Law and Jurisdiction

Determining which country’s law applies to the succession is critical. French and U.S. systems may lead to different outcomes depending on residency, nationality, and asset location.

Forced Heirship vs. Testamentary Freedom

French law imposes mandatory inheritance rules protecting certain heirs, while U.S. law generally allows greater freedom in estate planning.

Location of Assets (Situs Rules)

Assets located in France may be subject to French succession law and taxation, regardless of the owner’s nationality.

Taxation of Inheritance (France and U.S.)

Inheritance may trigger tax exposure in one or both jurisdictions, requiring careful coordination and planning.

Recognition of Wills and Estate Planning Documents

Documents valid in one country may not be fully effective in another without proper structuring.

Family Structure and Beneficiary Rights

Family relationships and heirship rights are interpreted differently across jurisdictions, impacting the distribution of assets.

Cross-border families face increasing complexity in succession planning.

U.S. estate tax threshold (federal exemption)

~$15 million per individual

France inheritance tax threshold

~€100,000 per child

Inheritance tax exposure in France

Up to 45% for children, 60% for non-relatives

Concrete Examples of Cross-Border Inheritance

U.S. Individual Owning Property in France

A U.S. citizen passes away owning French real estate. French succession law applies to the property, potentially altering the intended distribution under a U.S. will.

French Family with U.S. Assets

A French family inherits assets located in the United States, requiring coordination between U.S. estate administration and French tax and succession rules.

What Cross-Border Inheritance Really Involves

For Estates with Assets in Both Countries

The process involves determining applicable law, coordinating probate or succession procedures, and managing tax exposure across jurisdictions.

For Heirs and Beneficiaries

Heirs must navigate administrative procedures, legal requirements, and tax obligations in one or both countries.

Why an Attorney is so important

Cross-border inheritance is not simply a matter of applying one country’s law.

It requires understanding how multiple legal systems interact—and how conflicts between them are resolved.

Many estates encounter delays, disputes, or unexpected outcomes because planning did not account for cross-border complexity.

A strong attorney does more than administer an estate.
A strong attorney ensures that the succession is executed correctly across jurisdictions.

The Advantage of a Dual-Trained Attorney

French and U.S. succession systems differ fundamentally.

Without proper coordination, assets may be distributed differently than intended, or taxed inefficiently.

The issue is not only understanding each system.
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It is understanding how they apply simultaneously to the same estate.

We bridge that complexity.

We Handle the Entire Process
from Scratch to Finish

Step 1

Initial Cross-Border Inheritance Analysis

We assess applicable laws, asset location, and family structure.

STEP 2

Succession and Tax Exposure Assessment

We identify potential conflicts, tax implications, and administrative requirements.

STEP 3

Strategic Coordination Across Jurisdictions

We align legal strategies between France and the United States.

STEP 4

Documentation and Estate File Preparation

We assist with wills, declarations, and required administrative filings.

STEP 5

Coordination with Notaries and Authorities

We work with French notaries and relevant institutions to manage the process.

STEP 6

Asset Transfer and Compliance

We guide the transfer of assets and ensure compliance with tax and legal obligations.

STEP 7

Post-Inheritance Structuring

We advise heirs on structuring inherited assets for long-term efficiency.

Some Cross-Border Inheritance Questions, Some Atlantic Bridge Answers

Will French law apply to my estate?

It may apply to assets located in France or depending on your residency and connections to France.

Can French forced heirship override my will?

In certain cases, yes. Proper planning is required to manage or mitigate this impact.

Will my heirs be taxed in both countries?

Potentially, yes. Cross-border inheritance often requires coordination to manage tax exposure.

Can cross-border inheritance be simplified?

Yes, with proper planning and structuring, many complexities can be anticipated and managed.