Cross border estate planning in Scotland and France – navigating forced heirship
The Scottish Section is delighted to be running an online repeat of the successful in person event held in Edinburgh in December last year. This webinar focuses on French/Scottish cross border estate planning and succession issues with a particular focus on the challenges presented by forced heirship rules in both countries. We hope this will be of interest to members in other UK jurisdictions as well as in France.
Join Jessica Flowerdew, Senior Associate of Brodies LLP, and committee member of the Scottish section of the Franco-British Lawyers Society and Emilie Bensmihen, French Advocat at Buckles LLP as they discuss a comparison of forced heirship rules in Scotland and in France and how these might affect those with interests in both countries.
This webinar will help those with cross border interests or those advising clients with cross border interests understand rules of forced heirship in Scotland and France and the way in which these might have an impact on them or their clients so that appropriate estate planning measures can be put in place.
> Private International Law rules in Scotland and France and how these determine the law applicable to succession;
> Scottish Legal Rights;
> French rules of forced heirship;
> The French " prélèvement compensatoire" or " right of compensation" and how this might impact Scottish domiciled individuals with property in France; and
> The importance of bespoke expert advice in cross border estate planning.
Emilie Bensmihen, Buckles LLP: Emilie is a French native and qualified French Avocat since 2008. After practicing a few years in France and Luxembourg, Emilie moved to the UK in 2016 to work in the French team at Buckles Solicitors. Emilie is also qualified as a Solicitor in England and Wales. Her main area of expertise is French property and inheritance law. She advises UK residents/nationals on any issue related to French properties or French assets, including estate planning with a French element, administration of cross-border estates and separation with a French property. With a background in civil litigation, Emilie also advises individuals on contentious issues related to their French assets.
Jessica Flowerdew, Brodies LLP: Jessica is a Senior Associate in the Personal & Family team at Brodies LLP. She is qualified to practice in Scotland and advises a wide range of clients on all aspects of personal law include estate planning, inheritance tax, executry administration, trusts and issues affecting adults with incapacity. As a dual French/British national and fluent French speaker, Jessica has a particular interest in Scottish/French cross border estate planning and succession matters. She sits on the Scottish committee of the Franco British Lawyers Society.
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