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As of August 17, 2015, under E.U. directive 650/2012. French citizens having residency within another country, or U.S. citizens in France can use either country’s estate planning laws to govern the distribution of ALL of their assets including French-based assets. For French citizens in New York, this allows for significant planning opportunities. Practitioners will need to understand the contrast between the French heirship system and New York planning laws. This panel will outline the difference between the estate planning and estate tax laws between the two countries, and how the estate tax treaty operates for a decedent subject to estate tax in both countries.