[MRM]

If the money stays off shore there is no US tax. She can keep it in France and only pay whatver the French tax is. The estate may pay tax before the money gets to her, so the inheritence will be net zero tax to her in France. She can keep it there and spend it without any US tax consequences because US law doesn't apply to money that doesn't come into US jurisdiction.

US tax comes into play only if the money is repatriated to the US. I can't remember the rule on that. It's either treated as ordinary income, which has normal tax rates, minus any tax paid in France, or it's treated as an inheritance. The US does still have an estate tax, as most people know, but the excemption is currently $5 million, so the money might be tax free to her up to $5 million. I simply don't remember which it is.

Since that's a pretty big difference, she better not guess. She should go to a larger accounting firm that deals with this issue. They'll know the answer off the top of their head and hve the right form at their fingertips.