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The Cour de Cassation ruled that a Frenchman living in the US could disinherit his children as this is allowed under American law (but not French).

It said, however, this would not have been permitted if the children had been left in hardship as it would be contrary to the spirit of French law.

The EU regulation allows people to choose in a will the law of their nationality to apply to their estate or otherwise the law of place of residence applies to their will if no choice is made.