Inheritance Taxes Under Anglo-Saxon Regulations: Just as Johnny, Utilize the Benefits
Getting (Un)Fair Shares.
Cashing in on someone's estate doesn't play by the same rules everywhere. Sure, France's got your back if you're a kid eager for a piece of the pie, but kick back and relax in England or the States if you're the type to leave your fortune to whomever you fancy. Just don't forget that your move needs to be damn genuine or your kin might contest your wishes, like how David Hallyday and Laura Smet did after Johnny Hallyday, their father from different mothers, chose to zone out in California.
Hallyday's will - penned with the American law in mind - appointed his wife Laeticia as the sole heir, shrugging off his ex-kids. The French courts, though, ruled on May 29, 2019, that the singer's heart belonged to France. The Nanterre tribunal decreed that Paris was his main nest, given the lengthy string of concerts he performed there.
This isn't the only example. While Jean-Michel Jarre was gored by the American law when his father left everything to the widow in 2009, the European Court of Human Rights took his kids' side in 2024.
But here's the twist: A French law established back in 2021 has given the kids' rights a push for compensation. See, children who are unceremoniously elbowed out of an international inheritance can now, theoretically, claim some of the assets left in France. But catch this: the notary's not in the loop about foreign assets, crucial to calculating the pompous portions of the estate the kids are entitled to.
No Thanks, I've Got Mine.
Now, if you're all about disinheriting your kin, Anglo-Saxon legal systems are your pal. Countries like the UK and the US follow the deceased's wishes to a bloody T. But sometimes family members might try to pull a fast one on your will using, for instance, the 1975 Inheritance (Provision for Family and Dependants) Act in the UK.
Juxtapose that with Roman law countries, such as France and Germany, which are stingy with the "to each their own" thing. They've got strict forced heirship rules that force a larger portion of the estate to the children and spouses, regardless of the deceased's will.
But wait, where does one reside? The EU Succession Regulation, aka the Brussels IV, has your back. It simplifies cross-border inheritance by focusing on the deceased's habitual residence. Presuming they had their heart in, say, France, the French law applies to the succession. Just remember, you can choose another nation's law, but it needs to be in a will or a legally bindin' document.
Good luck with your inheritance escapades, and remember: where you lay your hat is where you hang your art. But watch out for those resentful kin lurking behind every corner.
Some Extra Tidbits:- Forced heirship variations: In France, Italy, and Poland, children and spouses must receive a sizable chunk of the estate regardless of the will.- Anglo-Saxon leeway: The UK, US, and Canada afford more flexibility in estate distribution, with few strict forced heirship laws.- Habitual residence: The EU Succession Regulation identifies a person's habitual residence for inheritance purposes, often focusing on the country where they had their heart during the final years of their life.
Sources:1. World Atlas - Forced Heirship2. Lexology - French Succession Law and International Assets3. Quora - Roman law vs Anglo-Saxon law4. DLA Piper - Inheritance disputes in France
Life insurance can play a crucial role in ensuring that the intended beneficiaries, such as your family or business, are financially secure upon your death, regardless of which legal system your estate falls under. For instance, if you're a UK resident and have life insurance, it can help cover any potential claims made under the 1975 Inheritance (Provision for Family and Dependants) Act.
On the other hand, finance and business planning can help you navigate the complexities of international inheritance, particularly when dealing with forced heirship rules in countries like France or Germany. For example, understanding the European Union Succession Regulation can help you determine the habitual residence of the deceased and apply the appropriate laws to the succession.
