Louisiana's forced heirship law does not extend to spouses. Movable property – personal property like money, furniture, or cars – is devolved according to … eur-lex.europa.eu La couleur de la Forced Rhubarb est renforcée par le processus technique utilisé, qui a également pour conséquence une peau fine et … Since the private law Similar rules apply in most continental European jurisdictions.Since that date, residents in EU countries (with the exception of the UK, Denmark and Ireland) have been faced with a single set of rules which govern the jurisdiction and applicable law in succession law matters. In the following pages we look first at the basic rules concerning inheritance laws in France, and then as they apply to particular family circumstances. The current rule : Forced heirship on French real estate As it stands now, French inheritance law divides an estate into two types of property: movable and immovable. In leaving the villa to Odile, Bernard Matthews had been aware that, under French laws of forced heirship, he could not cut his adopted children out of his French estate, and that his three children were entitled to 75 per cent of the villa, which would leave only 25 per cent of it to Odile. The dispute gave certain sections of the press a welcome opportunity to hone their literary skills ('Feathers Fly over Bernard Matthews' Turkey of a Will – Fowl Play Suspected', etc), but the serious issue was that Mr Matthews' intention to leave his French house to his long-standing partner, Odile, was thwarted by his adopted children's claim under French law to a 75 per cent share of the property.One note of warning, though: The French system of taxing French assets held in trust means that it will usually make sense to exclude French assets (or indeed assets in most European countries) from any will incorporating trust provisions, or from any 'pour-over' will decanting the estate into a lifetime trust. Until August 2015, where immovable assets (real estate) situated in France were concerned, it certainly did.The key point here for Singapore citizens is that anyone with a property in Europe (again, except for the UK, Denmark and Ireland) will be able to elect themselves out of the local forced heirship regime by specifying in their will that the law of their nationality should apply (at the same time it would be necessary to note whether or not the testator is a Muslim and whether the Administration of Muslim Law Act, Chapter 3 would apply to him).However, where the testator has elected for the law of his nationality to apply, the Regulation explicitly rejects any such referral, so that Singapore law (without forced heirship) should be applied by the local court.In the Matthews case, the children argued that the French tax should be payable by the estate rather than by themselves. They lost, but the arguments were complex and expensive.However, there would have been tax disadvantages, which is presumably why Mr Matthews (over-optimistically as it transpired) gave the children the benefit of the doubt that they wouldn't contest his wishes.The short point is that anyone owning property in Europe needs to appreciate that local forced heirship rules may apply when they die, and also that there may well be issues in connection with the international effects of official documents issued in the course of the administration of the estate, such as grants of probate, certificates of inheritance and statutory declarations.Cross-border estates are complicated and careful planning is vital to ensure that your estate goes to the people you want it to go to with the minimum of delay and opportunity for argument.Estate planning in an international context is seldom straightforward, especially when there may be family tensions.