Do you have clients with relatives, property, inheritances or business in Quebec or France? Learn about inheritance, tax, and planning strategies for residents and non residents.
We start with a comparison between a Civil Law Succession vs a Common Law Estate and the second part of our presentation is Preparing for France.
Part 1: Civil Law Succession vs Common Law Estate
- 70% of transfers of assets on death are governed by Civil Law
- What are the key differences between a Civil Law Succession and a Common Law Estate?
- Taxation on death in Civil Law jurisdictions: Succession Duties payable by the heirs
- Double taxation : Can\US\UK tax the deceased - Civil Law countries tax the heirs
- No domestic trusts in Civil Law countries ( except QC)
Part 2 : Preparing for France
- France is a unique tax jurisdiction : Succession Duties 15%-60% on gross assets
- If an adult child is transferred to France for work, what is the impact for Canadian parents and their estate planning ? is the child a beneficiary of a trust: annual disclosure to French Tax authorities
- If a Canadian wishes to acquire an apartment in Paris or a villa in the South of France : how to defeat Forced Heirship ? How to reduce Wealth Tax on real estate ( Impôt sur la fortune Immobilière )? How to reduce French Succession Duties ?
Louise Houle, LL.M., TEP - Avocate-conseil • Counsel
DE GRANDPRÉ CHAIT S.E.N.C.R.L./LLP - Montreal
Louise Houle is an experienced lawyer in the taxation team at De Grandpré Chait. Her practice focuses on tax and estate planning, especially for families holding real estate in Canada, the United States and Europe. She also advises wealthy families on matters pertaining to trusts as well as Canada-United States cross-border tax planning.
Louise has extensive experience in complex national and international business structuring and in estate planning. She is very familiar with matters relating to personal taxation and death taxes in Canada and the United States, inheritance and estate taxes in Europe as well as philanthropy, non-profit organizations and charities.
Louise was a partner with Heenan Blaikie LLP until 2014, then joined DS Avocats LLP (head office in Paris, France) and in 2018, joined De Grandpré Chait LLP. Louise was a member of the Board of Directors of the Québec Crown Corporation Investissement Québec (2008-2010). She was also a member of the Board of Directors (1994-1998) of Desjardins Venture Capital and of its Investment Committee (1999-2011). She has become familiar with governance and reporting for financial institutions. From 2004 to 2012, she served as member of the Board of Directors of Selwyn House School and The Study School Foundation (2004-2013).
Louise also represented numerous foundations and secretary of charitable organizations during her career. Louise was secretary of the Pierre Elliott Trudeau Foundation from 2001 to 2021, the Louise and Alan Edwards Foundation from 1999 to 2015 and of the Cree Community Foundation since 1998.
Marie Catesson head of Estate Planning at the law firm Fidal LLP - France
Sebastien Laisney, head of Taxation at Fidal LLP - France
Fidal is the largest law firm in France: 2,200 lawyers in 87 offices across France.
No charge for Estate Planning Council of Canada Members
Guests are welcome - this event is for Professional Advisors only.
Membership InformationYou can send this link to colleagues: https://www.epc-canada.org/event-5209461