Cross-border estates

French-law advice and coordination for estates involving several jurisdictions

A cross-border estate can quickly become complex where the deceased, the heirs or the assets are connected with more than one country.

I advise individuals, families and professional advisers on the French-law aspects of these matters and coordinate, where necessary, with notaires, foreign lawyers, executors, trustees and other professionals involved in the relevant jurisdictions.

When can I assist ?

I assist where an estate involves several jurisdictions or requires French-law advice in conjunction with professionals based in other countries.

heirs or beneficiaries live in different countries
the estate includes property, bank accounts, investments or other assets in several jurisdictions
the estate involves a foreign trust or another overseas wealth structure
a will was executed abroad or concerns assets situated in different countries
French assets form part of an estate administered overseas
several professionals are involved, including a French notaire, foreign lawyer or solicitor, executor, trustee or tax adviser
the French-law position needs to be analysed and coordinated with advice from local counsel in another jurisdiction

A coordinated approach to cross-border estates

Cross-border estates often require several professionals to work together and involve the interaction of different legal systems.

My role is to analyse the French-law aspects of the matter, identify issues requiring advice from counsel in another jurisdiction and assist with the overall coordination of the estate.

Depending on the matter, I may work alongside a French notaire, foreign lawyer or solicitor, executor, trustee, tax adviser or other professional involved in the estate.

For international advisers : I can act as French counsel on the French-law aspects of the matter, working alongside the lawyers, executors, trustees, notaires and other professionals responsible for the estate in the relevant jurisdictions.

Estates involving French Polynesia and overseas assets

An estate connected with French Polynesia may include assets situated abroad, such as property, bank accounts, investment portfolios, company interests or interests in a trust. These matters may involve jurisdictions such as Australia, New Zealand, South Africa or the United States, as well as France and French Polynesia. I advise on the French-law and French Polynesian aspects of the estate and coordinate with the appropriate local professional where the law of another jurisdiction must be considered.

property situated overseas
bank accounts or investments held abroad
foreign trusts
wills or estate proceedings in another jurisdiction
heirs or beneficiaries living overseas
documents or formalities requiring coordination between jurisdictions

Overseas heirs: estates and property in France or French Polynesia

I also assist heirs and property owners living overseas where an estate includes property, co-owned assets or other rights situated in France or French Polynesia.

These matters often require remote coordination with a French notaire, other heirs and, where appropriate, advisers in the client’s country of residence.

My work may include:

regularising an estate involving property in France or French Polynesia
assisting where some heirs live overseas
dealing with family co-ownership
division or sale of inherited property
coordination with the notaire and other professionals involved
remote assistance for heirs and owners living abroad

Consultations and professional communications can be conducted in English or French and arranged remotely.

Do you need French-law assistance with a cross-border estate ?

You can briefly outline the matter, the jurisdictions involved and the nature of the assets so that we can identify the appropriate next steps and professionals required.