Absolutely. On tax related topics I think a forum like ours should only be used as a way to gather valuable ideas on options and questions that should be posed to an independent tax professional.
Whatâs the value of the gift?
Hi yes it is,
349,000
I completely agree. Tax is one of those unfortunate areas that is most prone to âgolf club bar/pub talkâ along the lines of âmy accountant saysâŚâ If anyone is going to take a significant financial decision with tax consequences, have an opinion you can rely on from an appropriately experienced tax adviser (Full disclosure - I was, once upon a time, a tax adviser!). But the tax world is unfortunately full of people who are strong on their own countryâs tax knowledge, eg the UK, but are on much less comfortable ground when dealing with the absolutely crucial matter of how that countryâs taxes interact with the country youâre actually living in, eg France (and vice versa).
I would be looking for advisers with a strong professional network in both countries, with a healthy sized client base in both, highly familiar with treaty claims, international social security issues, cross border pensions issues etc etcâŚIn the international area, in my view, relevant experience counts for more than formal qualificationsâŚ
People will also have to accept theyâve got to pay appropriately. Remember George Sorosâs great quote that there are only 3 things in life that do not make sense to cut cost corners. One is open heart surgery. Two is your choice of parachutes. And three is tax adviceâŚ
We looked around for someone to advise on our wills, and asked questions of a number of experts. Including our local notaire who said he didnât have the experience to advise us. But most seemed very patchy - which is the advantage of an internet forum as you learn the questions to ask.
Ended up going to a UK firm who said they specialise in complex cross-border successions. Super-expensive!
It has simplified somewhat in recent years insofar as one can designate the regime under which the succession takes place, but competent professional advice is really the only way to ensure avoiding nasty surprises IMO.
That is currently in doubt because of the new French law that might overide everything else.
We started with straightforward wills specifying that should be British Law that governs, But quickly realised that for our family structure this wasnât enough.and sought specialist professional advice.
Bugger
The word âimmeubleâ (ie land/property/real estate/buildings) literally means âunmoveableâ in its origin.
Thatâs why Janeâs fear about removal of the option to choose your country of originâs law over Franceâs, for inheritance or any form of taxation, is so well-founded.
Property is literally unmovable, therefore it canât escape anything as it canât be moved away. It can always be grabbed or taxed because itâs literally⌠there.
Movable property, such as jewels, or intellectual property, is always practically be going to be harder to tax. Hence I was told certain ethnicities with a history of being persecuted, or âhaving to change countries every 50 yearsâ as my old-money German banker boss told me, often will ensure to store a chunk of their wealth in a portable form.
Not so with land & buildings. Canât be moved, so itâs just a matter of time before they will always come under tax, whatever concessions may have been made in the meanwhile.