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Estate Planning Council of CANADA

Quebec Successions in Civil Law + Estate Planning for France

  • September 20, 2023
  • 12:00 PM - 1:30 PM (EDT)
  • Virtual

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.

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 ?

Part 1:  Civil Law Succession vs Common Law Estate

Louise Houle, LL.M., TEP  - Avocate-conseil  Counsel


Marie Catesson head of Estate Planning at the law firm Fidal LLP

Sebastien Laisney, head of Taxation at Fidal LLP.

Fidal is the largest law firm in France: 2,200 lawyers in 87 offices across France.

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.

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