International Inheritance & Succession
An Inheritance That Crosses Borders Is Never Straightforward.
Someone has died, or you’re planning for what happens when you do. There’s property in France. There may be property in other countries too. The family is spread across different jurisdictions. And you’ve just discovered that French inheritance law doesn’t work the way you expected.
Perhaps you assumed you could leave your estate to whoever you chose — but French law reserves a mandatory share for your children. Perhaps you thought your English will would cover your French property — but it turns out the two systems don’t interact the way you imagined. Perhaps you’re an heir trying to deal with a French estate from abroad, and the administrative process feels impenetrable.
These situations are more common than people realise, and they are more complex than they appear. The interaction between French inheritance rules and the laws of other countries — particularly common-law countries like the UK, the US, or Australia — can produce outcomes that surprise everyone involved. Which country’s law governs the succession? Does EU regulation give you a choice? What about the tax implications in each jurisdiction?
The answers matter enormously, and they are different for every family.
A Former Notary's Understanding of Succession
Handling successions is one of the core functions of a French notary. Julie Gordon’s years in notarial practice gave her direct, day-to-day experience of how French inheritance works in practice — the procedures, the documentation, the coordination between parties, and the issues that arise when an estate involves foreign elements.
As a specialist in international law, she now focuses on the cross-border inheritance situations where standard domestic handling is not enough. She works with certain types of succession matters — particularly those involving an international dimension — and can advise on whether your situation falls within her area of expertise.
Situations We Work With
International inheritance raises different questions depending on the countries involved, the assets in the estate, and the family’s circumstances. Our clients come to us when they are dealing with:
An estate involving property or assets in France and at least one other country
French forced heirship rules that conflict with the deceased’s wishes or their home country’s approach
The question of which country’s law should govern a succession — and whether there is a choice
Wills that were drafted in one country but need to cover assets in France
The administrative process of dealing with a French estate from abroad
Planning ahead to avoid inheritance complications for international families
Your matrimonial regime directly affects what happens to your estate — for international couples, the interaction between marriage contracts and inheritance rules across borders can produce unexpected results. → Nuptial Contracts for International Couples
Planning ahead also means considering what happens if you lose the ability to manage your own affairs before the inheritance question arises. → Support for Vulnerable Persons
Contact Us
If you’re dealing with an inheritance that involves France and at least one other country — whether you’re planning ahead or managing an estate now — contact us for a consultation.