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Login to watch this video if you have a subscription. Learn more about subscriptions.Do you have clients with relatives, property, inheritances or business in Quebec or France? This program explains inheritance, tax, and planning strategies for residents and non-residents. The first part compares a Civil Law Succession and a Common Law Estate, highlighting that 70% of transfers of assets on death are governed by Civil Law. It examines the key differences between these systems, the taxation of death in Civil Law jurisdictions where succession duties are payable by heirs, the issue of double taxation when common law countries tax the deceased while Civil Law countries tax the heirs, and the absence of domestic trusts in Civil Law countries, except Quebec.
The second part focuses on preparing for France, a jurisdiction with succession duties ranging from 15% to 60% on gross assets. It addresses the implications when an adult child relocates to France for work, the disclosure obligations to French tax authorities if the child is a trust beneficiary, and the impact on Canadian parents’ estate planning. It also considers the challenges faced by Canadians who acquire property in France, including how to defeat forced heirship, reduce wealth tax on real estate (Impôt sur la fortune immobilière), and reduce French succession duties.
Presenters are Louise Houle, LLM, TEP, Avocate-conseil, Counsel, De Grandpré Chait S.E.N.C.R.L./LLP, Montreal; Marie Catesson, Head of Estate Planning, Fidal LLP, France; and Sebastien Laisney, Head of Taxation, Fidal LLP, France. Fidal is the largest law firm in France, with 2,200 lawyers in 87 offices across the country.
Louise Houle is an experienced lawyer in the taxation team at De Grandpré Chait. Her practice focuses on tax and estate planning, especially for families holding real estate in Canada, the United States and Europe. She also advises wealthy families on matters pertaining to trusts as well as Canada-United States cross-border tax planning.
Louise has extensive experience in complex national and international business structuring and in estate planning. She is very familiar with matters relating to personal taxation and death taxes in Canada and the United States, inheritance and estate taxes in Europe as well as philanthropy, non-profit organizations and charities.
Louise was a partner with Heenan Blaikie LLP until 2014, then joined DS Avocats LLP (head office in Paris, France) and in 2018, joined De Grandpré Chait LLP. Louise was a member of the Board of Directors of the Québec Crown Corporation Investissement Québec (2008-2010). She was also a member of the Board of Directors (1994-1998) of Desjardins Venture Capital and of its Investment Committee (1999-2011). She has become familiar with governance and reporting for financial institutions. From 2004 to 2012, she served as member of the Board of Directors of Selwyn House School and The Study School Foundation (2004-2013).
Louise also represented numerous foundations and secretary of charitable organizations during her career. Louise was secretary of the Pierre Elliott Trudeau Foundation from 2001 to 2021, the Louise and Alan Edwards Foundation from 1999 to 2015 and of the Cree Community Foundation since 1998.