International executives: why succession is becoming a strategic issue
- 5 days ago
- 3 min read
More and more executives are living across multiple countries. Residence in Canada, company in France, investments in the United States: wealth management structures are naturally becoming international.
This reality creates a major challenge that is often underestimated: international inheritance taxation.
Unlike a domestic inheritance, several tax authorities may claim the right to tax. In some cases, the interplay of national rules can lead to complex situations that may prove costly for the heirs.
The three factors that determine the taxation of an international inheritance
In most tax systems, three criteria determine the competent jurisdiction.
The tax residence of the deceased
Tax residency at the time of death often plays a central role. Some countries tax the worldwide assets of their residents.
The location of the properties
The presence of real estate or financial assets in a country may give that country the right to tax those assets.
International tax treaties
Some tax treaties organize the allocation of taxing rights between States in order to avoid double taxation.
However, these conventions do not always cover all situations.
Comparison of inheritance systems
France vs Canada vs United States
France | Canada | UNITED STATES | |
Inheritance tax | Yes | No | Federal Estate Tax |
Tax principle | Territory + residence | No direct inheritance tax | Estate tax with high abatement |
State tax | No | No | Possible depending on the state |
Taxation upon death | Inheritance rights | Potential taxation of unrealized capital gains | Estate tax based on property value |
Impact for expatriates | Assets located in France are taxable | Inheritance is generally not taxed | Taxation depends on tax status |
France and international succession
France applies a principle of territoriality.
This means, in particular, that:
Assets located in France can be taxed even if the deceased lived abroad.
Tax residency can trigger worldwide wealth taxation
For expatriate entrepreneurs, the presence of assets in France therefore remains a determining factor.
Canada: a very different system
Canada generally does not apply direct inheritance tax.
However, upon death, certain tax rules may lead to the taxation of unrealized capital gains on assets. This mechanism can have a significant impact depending on the estate structure.
👉 Detailed analysis:
United States: The logic of the “estate tax”
The American system is based on a federal estate tax with a high allowance before taxation. Some states also apply their own estate taxes.
For international executives, the combination of French and American rules may require a specific asset structuring.
👉 Detailed analysis:
Common mistakes in international successions
Several situations regularly arise among international entrepreneurs.
Do not anticipate tax residency at the time of death
Tax residence can completely change the taxation of inheritance.
Underestimating the impact of asset location
Owning real estate in France can be enough to trigger French taxation.
Ignoring tax treaties
Conventions can limit or distribute taxation between countries, but they often require careful analysis.
How to structure an international succession
For an international leader, several levers can be used.
clarification of tax residence
structuring of heritage assets
estate planning
drafting wills compatible with multiple jurisdictions
Inheritance then becomes a matter of estate planning, and not just taxation.
Conclusion
In France, Canada and the United States, inheritance rules are based on very different tax principles.
For international executives, the issue is not simply comparing tax rates. It is primarily about organizing a wealth structure consistent with an international lifestyle.
Anticipating these issues helps to avoid tax conflicts, secure the transfer of assets and protect the continuity of family businesses.
Do you live between France, Canada or the United States and is your wealth spread across several countries?
International succession requires coordinated analysis between several jurisdictions.
Blendy assists international executives in the tax and wealth structuring of their activities between France, Montreal and Miami.
👉 Get in touch with our team to analyze your situation.
Sources:
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