Need French Will?

I understand the law changes this year [August] and you can specify the country {& will] to handle your estate. Our situation is this:

  • my wife & I both are American citizens, However I also am a UK citizen [have 2 passports]

  • we live in US currently but may start spending less that 180 days/year in France

  • we have US wills

  • we have no joint children but some from previous marriages wife - [3] and me [1 ] - all adult


  • Should we have a french will?

  • Are our US wills adequate?

Any wisdom welcome


It does not cost much to have wills registered in any of your nations, so based on personal experience I would say do it, and to satisfy the French make them all hand written. My husband’s American will was refused because it was typed. Yep, true!

That is the direction we were thinking but I suspect it will be difficult to avoid cross-border discussions. My notaire suggested we just write out our will and let him register it. Is that the correct way?

Timely question! We were just talking about wills this past weekend. My husband & I are both US citizens, & he also has Irish nationality. We live in France full-time, rent an apartment & don't currently own property in either the US or France. Our US assets consist of retirement fund accounts (mostly IRAs) while the contents of our household + a car comprise our French assets. My stepdaughter is our sole beneficiary so it should be simple, especially as she is already listed as the beneficiary on the accounts mentioned above. Should we have a US will, a French will, or both? Do we need to appoint executors in both countries? Thanks for your guidance.

The last thing you want is for lawyers to be working across borders because that will burn money. I would advise you to make a will in each country where you have assets and to make sure that your executor/s are aware of the fact. You could have different executors in each country also so that there is absolutely no cross-border stuff. I have one UK will and a French will both drawn up on that basis. Hope that helps.