We’ve been trying to find an advisor who has some knowledge of France, Portugal, and USA.
We are buying a house in Compiegne, France (which we will rent for 3 years until we can live there), and we are also becoming Portuguese citizens. We need advice on where best to “officially” settle because I’ve recently heard about the fairly extreme France inheritance laws (our French friends are currently dealing with this and are very frustrated). So our options for having our official domicile is France, Portugal, the US, or potentially another European EU country where living expenses are low and inheritance laws will meet our unique situation.
As a bit of background, we have 2 adult sons with high functioning autism and they were recently diagnosed with a rare debilitating disease (like MS or ALS) that will likely result in them at a minimum becoming wheelchair bound, worst case they will need full time 24-hour nursing care. Because of their lifelong autism, we have long held the majority of our assets in a revocable Living Family Trust (under California law) with guidance for their care if we become deceased. My research has shown that France does not have such a trust option, however, there must be some method for dealing with offspring who inherit money but cannot manage their finances or lifecare on their own.
Ideally, we would find a financial and tax advisor with knowledge of all 3 countries, but I know that’s asking a lot. Thank you so much for reading and please reply if you have an suggestions where to find someone.
Frankly, I don’t think anybody here can help you with that. Getting an advisor that is competent in two countries, say the UK and France or France and the Netherlands, is relatively easy, but three countries, the US, including trusts, France AND Portugal is asking too much of small operators IMO.
Until I retired and things got simple my tax advisors were KPMG. Expensive I know but they have expertise and representation in all the jurisdictions you mention. I think you need one of the big four to competently cover the breath of your requirements. Mistakes or bad advice can be very costly.
Others here may disagree, but that’s fine, this is just my advice
You say “options” for where you are considered domiciled but in general this is a matter of fact, not choice. If you choose to settle in France and make this the centre of your economic and personal life you will be resident here, have this as your primary tax address, and then French law will prevail on inheritance.
And yes, French inheritance law has its issues. But if you are married and neither of you has other children from previous relationships then your succession will be pretty straightforward
I’d look at being technically resident and/or domiciled (though the difference seems to be disappearing in some ways) in a completely different jurisdiction if you’re rich enough. You’d have to be well advised so you could carefully count days in and out of each of the countries you do spend time in and usually the exact time (hours) on the arrival day each time. As some countries count days different ways.
I know this is possible because in a number of investment banks and a few other places I’ve worked with people who managed it. One in particular seemed to have managed the holy grail of not actually living anywhere .! It seemed quite frequent that PWC/KPMG advice was paid for by the institutions they worked for or were associated with.
This may or may not work well with how you want to live in retirement. You may not want to travel, or you may want to be in one country’s tax or medical system for peace of mind, for example.
PS USA is the biggie as I gather the US likes to tax its citizens no matter where they live in the world. In the finance world sitting in the UK, and a bit of a few other industries over decades professionally, again and again I’ve observed providers of all sorts of things, including advice, financial products or just regular products, withdraw from discussions saying “that touches America. We can’t take that on.” So actually, I’d start with an adviser on my exit from US tax, potentially, first.
PwC, KPMG, EY and Deloitte are the Big Four global accountancy, tax and audit networks, each with representative firms in about 170 countries. (Full disclosure: I’m a former tax and risk management adviser in one of the Big Four, who worked in the UK and France.)
I think John’s and Karen’s advice to approach them is sensible. They will have the necessary legal and tax expertise in all those jurisdictions (or can call in specialists from elsewhere for particularly niche technical issues). One major advantage is that you should get coordinated, joined up advice by this route. I doubt any one stand alone local (ie non Big Four) firm in any one of those jurisdictions could possibly provide joined up global advice of this nature.
That said their cost base is set up primarily to deal with multinationals and wealthy individuals, so whilst you should get the service and quality advice you need, you would obviously have to be prepared to pay fairly substantial fees.
There are small private highly specialised firms in places where there is demand (and enough wealth) who do provide this advice. Some will even cover all 3 countries, especially as Portugal received a lot of attention from incomers including Americans, since Covid as there were particularly low taxation rates there.
Finding these firms is normally done by recommendation. Either they serve generations of your family, or the highly discreet Private Bank you’re a customer of refers you, or you have a solid gold reliable recommendation from someone with a similar wealth profile. All should be treated with caution especially the last one. As what you’re buying from the Big Four is depth, existing processes and connections they’ve used before, possibly range of countries and above all, their Professional Indemnity policy and to an extent (depending on who you are) their continued good reputation.
Point 2 is incorrect. You absolutely need to choose the correct parachute for your weight and the type of jump that you plan to make.
My younger self was once given a 32’ diameter parachute and told the landing would be “brisk”. If I had to use the 24’ diameter reserve parachute, I was told “You’ll live, but unless you absolutely nail the landing, you’ll be breaking at least one leg.”
Not silly, I will never go up in another aeroplane. Not quite as bad as my mate Pete who always said he got a nosebleed on a shagpile carpet, but I do not like heights.
I’m just wondering if there might be a difficulty for your children, if they cannot understand the people who are trying to help/care for them (when you, their parents, are no longer alive).
Only you fully appreciate what your children can do and whether or not they understand a particular language.
I’m just floating the question of which country they might be happier in, when they find themselves alone. That country might be the best one in which to arrange your Family Trust etc.
.! It seemed quite frequent that PWC/KPMG advice was paid for by the institutions they worked for or were associated with.
