Foreigners Living or Investing in France, and French expatriates: What are the pitfalls and how to avoid them?
The Covid pandemic has only temporarily slowed international travel and expatriation, which has increased dramatically with advances in technology, social media and the mobile economy. In 2019, an estimated 9 million U.S. citizens lived overseas, with 20,690,491 U.S. passports issued— a 47 percent spike from 2014.
As much as these advances have decomplexified international mobility, Multi-National Families; Citizens, Residents in France, and French abroad end up living in a complex cross-border environment. Many are unaware of how their nationality and place of residence can impact their lives and financial future. Legal and HR counsel of their country of origin are often equally unaware of how choices such as which marital contract, or estate planning framework, can interact with local rules.
If you are, or counsel, someone with an international mobility or investment project i.e. an American with investments or moving to France, a French citizen moving to the United States or Europe, and cannot answer the below questions, this webinar is for you:
- What is a matrimonial regime?
- What is the European Union Regulation on cross border successions?
- How what does bare ownership and forced heirship mean?
Our panel of experts will cover the following topics:
- Anticipate with a marital contract
- Clarify/regularize the current situation (post nuptial agreement, declaration of applicable law)
- Divorce procedure strategies
Transfer by inheritance : How to anticipate ?
- Transfer of an estate or transfer to heirs – how to avoid a grant of probate
- Should testator choose the law applicable to the transfer of his/her inheritance?
- Is it advisable to create a Trust (only on civil point of view) when France is involved?
- Should American citizens fear French hereditary reserve/forced heirship?
Examples of national specificities / particularities of each system which do not export well:
- Tax planning for US citizen relocating to France: benefits of becoming French tax residents and do’s/don’ts before moving
- Trust : how are they treated in France, what precautions need to be taken?
- Bare ownership/usufruct
Delphine EskenziPartner, Libra Avocats, Paris
Admitted to bars of New York and Paris since 2004, Delphine holds a master’s degree in law from the University of Paris I – Panthéon Sorbonne and an American law degree from Cornell Law School (JD, Summa Cum Laude) and often advises clients on issues related to marriage contracts or prenuptial agreements in an international context.
Sophie Ducamp MonodFounder, Ducamp Monod Notaries, Paris
Sophie accompanies her clients with administrative procedures for life milestones: marriage contracts, PACS, divorces, wills, successions, donation, real estate purchases. She has extensive civil and tax experience in the acquisition and sale of real estate by non-residents in France, in inheritance anticipation involving transnational interests, in the settlement of estates of deceased persons in France, with assets outside France or with deceased outside France with French assets.
Stéphanie AuferilPartner, Arkwood, Paris
Stéphanie advises families on all their wealth management tax matters, notably cross border. In particular, she assists numerous US citizens with their relocation to, or investments in, France, as well as French individuals relocating or investing in the US. She also advises on wealth planning via trusts for foreign families, notably US citizens with French connections, and assists families and family businesses in their structuring, development and estate planning in a domestic and international context.