Global families are more common than ever. With homes in multiple countries, international marriages, and assets abroad, inheritances increasingly cross borders. But international estates come with unique challenges.
The Issues at Hand
- Different Probate Systems – Each country has its own legal rules.
- Tax Complications – Heirs may face double taxation without proper planning.
- Conflict of Laws – Determining which country’s law applies can be complex.
- Language Barriers – Documents may need translation and validation.
Examples
- A U.S. citizen with a vacation home in France may trigger French succession laws.
- A Canadian inheriting U.S. property may owe taxes in both countries.
Solutions
- Hire International Estate Attorneys – Specialized knowledge is critical.
- Use Treaties and Agreements – Some countries have tax treaties to prevent double taxation.
- Plan Early – Cross-border families should create coordinated wills in all applicable jurisdictions.
The Big Picture
As families spread across the globe, international inheritance is no longer rare. Addressing it now ensures heirs won’t face a legal maze later.
