Inheritance of a property bought by an English married couple

Example: If a couple got married in England and their marriage is governed by English law which retains separate estate system. French law recognizes the separates estate system, and in the case of the inheritance of a property, the surviving spouse inherits of the « usufruit » which reserves the right of the surviving spouse to continue […]

The rules of inheritance of a French Property

The issue is to determine the surviving spouse’s right over the French Property. I have chosen to analyse (a) the French regime which applies the principle of lex rei sitae, followed (b) by the legal certainty you may find in choosing, under the Regulation, the applicable law of succession, and (c) the current tax law […]

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