Multi-jurisdiction inheritance question

Gerbert

Mr X is a citizen of one EU country but has been living in another for many decades.  He owns property in his birth country and also in the UK.  Similarly he has other financial assets in all three countries.  He has two children who will inherit his estate in equal shares when the time comes.

Questions:

1. Under the legal jurisdiction(s) of which countries will his estate be managed on his demise?
2. What are the implications for how his will should be structured?

All ideas gratefully received.  It is not even clear (to me anyway) in which country a solicitor should be contacted to advise on this.

DE_612183

Not entirely sure but I think the estates for each country are treated separately.

You'll need a specialist law firm to deal wit this - law society may be able to help?

poseidon1

Gerbert said:

Mr X is a citizen of one EU country but has been living in another for many decades.  He owns property in his birth country and also in the UK.  Similarly he has other financial assets in all three countries.  He has two children who will inherit his estate in equal shares when the time comes.

Questions:

1. Under the legal jurisdiction(s) of which countries will his estate be managed on his demise?
2. What are the implications for how his will should be structured?

All ideas gratefully received.  It is not even clear (to me anyway) in which country a solicitor should be contacted to advise on this.

Only mentioning the UK provides no basis for offering a meaningful view of how complicated this gentleman's estate planning and ultimate administration of his estate would become.

Can certainly suggest that he should have a UK will covering the UK property, bearing in mind if it's value exceeds his nil rate band, it will almost certainly be liable to IHT.  Wealthy non doms use to use  offshore structures to avoid this.

 If taking advice on a UK will he should consult a STEP qualified solicitor with specific experience in multi jurisdictional estate matters - this tends to point towards the larger London private client practices.

If this gentleman is overall of modest means and cannot afford expensive crossborder estate planning advice, perhaps he should be looking to make predeath gifts ( as far as he can) to rationalise his estate on behalf of the children.