Taxation & Estate Planning

Inheritance Laws and the EU

By Joel A. Schoenmeyer

The Economist's Charlemagne blog has a really interesting article this week about the European Commission's guidelines for inheritance involving assets in more than one EU country. The link is here.

As the article indicates, this is really a dispute between Britain (England and Wales) and the other 26 EU countries. Most EU countries have some form of forced heirship -- that is, the decedent's children must inherit a portion of the estate (in equal shares), and -- with some rare exceptions -- cannot be disinherited. Such a concept of "forced heirship" is totally alien to people in Britain and in the US (and, obviously, our concept of total testamentary freedom is foreign to the other 26 EU countries).

Full post as published by Death and Taxes Blog on October 21, 2009 (boomark / email).