Article 751 of the French General Tax Code
For tax purposes, any transferable security, movable or immovable property belonging to the deceased as usufructuary and to one of his presumptive heirs or their descendants as bare owner, even if excluded by will, or to his instituted donees or legatees, even if by a later will, or to interposed persons, is deemed to form part of the usufructuary’s estate until proven otherwise, unless there has been a regular donation…