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UK/Foreign Situs Will + Pet Trust: . Seeking advice on STEP solicitors
Hi everyone,
I am a 49M British citizen in excellent health. I am currently mapping out a multi-jurisdictional estate plan. I recently had a consultation with a local UK high-street firm, but as soon as I mentioned that I have assets abroad, the legal assistant panicked, said they "don't do cross-border work," and completely failed to understand that I am already hiring a separate, local lawyer to handle my foreign properties.
I want to bypass these basic high-street generalists. I’m looking for advice from anyone who has successfully coordinated a similar multi-will setup, or recommendations on finding the right boutique legal help.
My Situation:
UK Assets: A flat and a current bank account.
Foreign Assets (Country A): Two residential properties. I am already hiring a local lawyer in Country A to draft a local Will under their specific laws to override their default intestacy rules (which would otherwise force my estate to my estranged mother).
The Goal: I want to completely exclude my mother and her side of the family (prolonged estrangement, zero financial dependency).
The Care Plan: I have a partner/caregiver in another jurisdiction (Country B) who looks after my 10 dogs. I want the bulk of my UK estate to fund their long-term care.
What I am trying to build (The Estate Architecture):
- Separate "Situs" Wills: I need a UK Will that *onlycovers UK assets, with a highly restricted revocation clause so it doesn't accidentally cancel the foreign Will being drafted in Country A (avoiding the classic "revocation trap").
- UK-Seated Discretionary Trust: Country B (where the dogs are) does not legally recognize private trusts. Therefore, the trust must be written into my UK Will. The UK trustees will hold the capital and drip-feed maintenance stipends to my partner abroad, strictly conditional on the ongoing care of the dogs, with a registered animal charity named as the backup beneficiary.
- Insulating against family challenges: I want a formal "Letter of Wishes" alongside the UK Will to defeat any future dependency claims under the UK's Inheritance Act 1975. Since I am only 49 and healthy, I want to avoid paying for an unnecessary private medical assessment. I need the solicitor's internal attendance notes to be robust enough to prove capacity.
- Draft Review: A simple coordination check where the UK solicitor reviews the revocation clause of my foreign Will draft (written by my local lawyer in Country A) purely to ensure they don't clash before I sign either.
My Questions for the Community:
Has anyone successfully set up separate "situs" wills for different countries? How did you ensure your lawyers in both countries coordinated the revocation clauses properly?
How do you find a boutique, trust-focused UK solicitor (ideally STEP-qualified) who actually understands cross-border coordination but charges reasonable, flat fees rather than elite city-firm prices?
How can I ensure the UK drafting solicitor takes sufficiently robust capacity notes to protect an unconventional Will (pets over bloodline) without requiring a formal medical assessment?
For those with pets abroad, is a UK-seated discretionary trust sending stipends to a foreign caregiver the most secure way to handle this, or is there a simpler legal mechanism I'm overlooking?
Thanks in advance for any insights!
Comments
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I'm not surprised that the legal assistant ran away and hid.
Good luck.
5 -
Start by asking your local lawyer in country A if they already work with any UK and/or country B lawyers? Or have you done that already?
0 -
Unfortunately I suspect that for what you want, it's the city firm that deals with high net worth individuals, rather than a high street firm... And it will come at a relatively higher cost as a result.
0 -
You could try searching here: https://www.step.org/directory/members/search and use the filter with: cross-border estates.
1 -
If you are estranged from your mother and other family I don't believe an application against your estate could be made:
As other responders have suggested, speaking to a STEP qualified solicitor who advertise that they deal with cross border estates in the best way forward here.
0 -
What is missing from your summary of personal circumstances is the current value of your worldwide estate for IHT purposes; does Country A have a death duties regime which may require funding from the UK estate; whether you are married to your partner/care giver ; whether the UK trustees you have in mind will have the requisite competencies to administer a discretionary trust and finally who will be the default beneficiaries after all the pets have died.
Since you have not mentioned UK inheritance tax at all, I do wonder if your collective worldwide assets are below the £325k threshold.
in any event the specialist cross border estate and tax planning services you are seeking will only be available on a time cost basis ( cannot imagine any firm worth its salt considering a fixed fee arrangement given the level of due diligence you expect of them).
All in all this does rather point to expensive central London private client firms.
As for a trust wholly devoted to the care and wellbeing of your pets, this is not unusual, and certainly not a desire which would require an assessment of your state of mind in the UK. In this regard you may find the following thread from the STEP Trust Discussion forum of interest -
4
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