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Estate between France and USA, the role of the lawyer.

Home > Inheritance and succession | Published 2018-05-18

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While many French people wish to live the “American Dream” by settling in, working or investing in the US, similarly some Americans have chosen to settle in France after being attracted by the beauty of the French way of life. Heirs to an international estate between these two countries can be confused, due to the complexity of the situation. Hence, who may be better than a lawyer to assist you in these sensible matters?

The French and American legal systems are quite different. Therefore, estates subject to the law of these countries need to be handled according to international elements and differences between the French and American Inheritance law.

Indeed, as an heir, you are entitled to the right of legacy. But this right can be seen differently in France and in the U.S. To ensure your rights, you must determine the relevant law of the estate, beforehand. In some situations, the EU regulation n°650/2012. of July 4th, 2012 related to estate may apply. This first step can be resolved by a lawyer, who has an expertise in trust and estate.

Then, as a legal expert, a lawyer can help you defend your rights on the estate’s assets located in France or in the US. He will do everything he can do in order to mediate the estate. For example, he can secure your French or American documents by the seal of apostille that notarize foreign documents in another state, which is often required by foreign and French authorities.

Finally, a tax lawyer can help you with legal mechanisms to lower the inheritance tax and avoid double taxation, by a thorough scrutiny of the treaty on international taxation between France and the United States.

For many years, Picovschi Lawyers has handled a variety of complex cases in International Estate. Our estate and inheritance department, as well as our tax law department, are working together to advice and assist you throughout the procedure. Our work is done, only when you get what you are entitled to deserve. 

This article is available online for public information purposes. It is updated regularly, as needed. Due to the constant evolution of the laws and the legal system, we cannot guarantee that the information in this article is still applicable. We invite you to contact us with any legal questions or concerns you have regarding this topic at +33 1 56 79 11 00. In no way can this firm be held liable for articles that contain inaccuracies or are now out of date.

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