Accueil > International Trust & Estate Planning
International Trust & Estate Planning
To know where to start...
Managing international assets can quickly become overwhelming, especially when family interests are involved. Navigating international estate plans requires a thorough understanding of estate laws and the legal frameworks of each foreign country where assets are held (such as a foreign property, a family business, or financial assets).
Every person involved must ensure compliance with the relevant jurisdictions to safeguard their legacy and guarantee a seamless transition.
Lettre & Brown offers tailored guidance to simplify the intricate process of international estate planning and protect your interests at every step.
Definition of international estate
An international estate occurs when the assets of the deceased are located in multiple countries or when the heirs live abroad. This situation requires a rigorous approach to comply with applicable laws and avoid any conflict of jurisdiction.
In this context, the international dimension of an estate poses complex challenges in terms of inheritance law.
It is essential to take real estate and movable assets spread across different countries (and consequently, different legal systems) into account. The role of the notary specializing in international estate planning is to facilitate the management of inheritance assets while ensuring compliance with applicable laws and inheritance rights.
Entrusting this mission to a notary therefore makes for a smooth transition of assets.
An estate with or without a will
The management of an international estate varies considerably depending on the presence or absence of a will.
Each country has its own inheritance law, some including specific rules such as the reserved portion of an estate (in France), double taxation rules, or gift taxes. Thanks to a notary specializing in international succession, heirs benefit from specific advice for optimized estate planning and transmission in accordance with legal provisions.
How is international estate planning managed ?
The testator can choose a single law to govern their entire estate, even if inheritance assets are located in multiple countries or provinces. Let’s take the example of a Quebec resident who owns real estate in Europe and movable assets in Quebec. By designating Quebec law as the applicable law, the estate is simplified.Benefit from the support of our notary
Entrusting the management of international successions to our notary office means choosing personalized support for your estate, in accordance with all legal provisions. Thanks to our expertise, we guide you in the transmission of your estate, whether it’s a family home abroad or a complex community of property.
Ensuring a smooth transfer of wealth requires addressing the needs of the beneficiaries and individuals involved while planning for the next generations. Harmonizing domestic and foreign assets requires a deep understanding of heirship rules. Seeking expert legal advice is essential to ensure compliance and facilitate a smooth estate management process.
With careful consideration of all factors, Lettre & Brown helps secure your estate for an efficient and thoughtful succession process.
Our team
We are your family notaries. We can help you.
Our services are available in our offices or remotely. Do not hesitate to contact us.