International will/estate planning

An international will ensures assets in multiple countries are distributed according to your wishes. Different countries have different inheritance laws, and a will valid in one country may not be recognized in another.

12 steps across 2 sections

1. Steps Process

  • Inventory assets by country — List all assets in each country.
  • Research inheritance laws — Check for forced heirship rules (France, Spain, Italy, Germany, Middle East, Latin America).
  • Decide: single or multiple wills — If multiple, ensure they do not accidentally revoke each other.
  • Consult attorneys in each country — Cross-border estate planning requires expertise in each jurisdiction.
  • Draft and execute — Follow execution requirements of each country (witnesses, notarization, language).
  • Register the will — Some countries require registration with a court or notary.
  • Review regularly — Update when assets, family, or laws change.

2. Key Details

  • Forced heirship: Many countries require portions go to children/spouse regardless of will
  • Each country may require separate probate
  • US estate tax applies to worldwide assets of US citizens
  • Community property presumptions vary by country
  • Include digital asset provisions

Common Mistakes

  • Assuming US will covers foreign assets
  • Not accounting for forced heirship
  • Multiple wills accidentally revoking each other
  • Not considering tax implications in each country

Pro Tips

  • Include clause in each will stating it applies ONLY to assets in that country
  • Consider appointing executors in each country with significant assets
  • Powers of attorney may also need to be country-specific

Sources

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