Aug 1, 2007 12:00 PM, By G. Warren Whitaker partner, Day Pitney LLP, New York, and Jean-Marc Tirard partner, Tirard Naudin

By: By G. Warren Whitaker partner, Day Pitney LLP, New York, and Jean-Marc Tirard partner, Tirard Naudin

Thomas Jefferson did it in the 1790s. Ernest Hemingway did it and wrote about it in the 1920s. Today, as well, many Americans move to France to live. Wealthy Americans often purchase homes there, which they visit parfois (occasionally). Some Americans even marry French people. And because the United States and France have fundamentally different legal systems, one based on common and the other on civil law, with two very different taxation regimes, the resulting tax and legal complications can be effrayant (frightening).

Alors, il est important de connaître (therefore, it's important to understand) the special estate and income tax planning issues that confront U.S. citizens — who reside in France, own real property in France or marry a French citizen — and some of the techniques available to address those issues.

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