That is something I never thought of. Interesting. So do you need to write a will in the places where you own property? In the US, the laws differ by state, but they all have laws that take over if you don't have a will. That's the situation you are describing, since the will in your own country doesn't count. We also have states where distribution laws override the will. For instance, in Pennsylvania, if you are married, one third of your estate must go to your wife, and if you have minor children, one third must be divided among them (or something close to that). Do the laws in France override any will you might make, too?