QUOTE(jkatow @ Jun 25 2006, 04:53 AM)

Karen
Thanks for your reply. What is the Napoleonic Code? I have found people who establish an American LLC and sell partnerships, taking care of taxes etc. Does this get around that?
J
I don't know what, if any, impact a US LLC would have under French law.
Another structure to use is a "Societe Civile Immobiliere" or SCI, which, if properly done, allows the owners of property to treat transfer on death of an owner under the rules of the country in which the deceased was a tax resident. In other words, a US citizen who held property in France through an SCI would, upon death, have the transfer treated under US rules, thus avoiding the French laws and Napoleonic rules.
If you get anywhere near serious on this stuff, you really need a notaire who is experienced in the field. We were fortunate to find a very good one who had worked with one of the large US accounting firms, and who understands French realty and estate matters and how they impact tax residents of other countries.
Thanks for the info. Would you be able to give me the name of your notaire??