In the US, your assets pass into an estate that can take years to settle. France works on a principle called "le mort saisit le vif," meaning heirs are entitled to assets the moment someone dies, no settlement period, no estate as a separate legal entity. Taxes are then assessed on each individual heir's share rather than on one pooled estate. It's a genuinely different system, and it matters most when a US estate plan meets it for the first time.
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