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International Estate Planning - with a
US twist
International Estate Planning is a complex topic. Some of the problem areas we routinely see are:
 Domicile.
Identifying your domicile and its consequences is the first step in planning for the estate of an International Family. Domicile is a status that can be difficult to change but with proper planning in can be done fairly quickly.
An example, of the importance of domicile is that in the US can you pass $3.5 million in property free of estate tax if domiciled in US but if not, the number is $60,000 (the tax base is narrower, however). Domicile will also determine what jurisdiction has the primary role in administering your estate and otherwise dealing with your will. For further information please click on link below: Briefing Note: "Foreign Pensions".
Multiple v Single Will.
For those with assets in multiple jurisdictions a significant question is whether a single will (with focus on law's of domicile) is better than multiple wills (where assets are located). There is no standard answer, expert advice is needed.
Trusts.
The tax and legal effects of a trust can vary dramatically
if a settlor/grantor, trustee, or even a beneficiary moves to a new jurisdiction (a change in tax residence or domicile). Most countries have punitive legislation when it comes to trusts that are deemed to be "offshore"). The US for example has a system of penalties that start at $10,000 for a simple failure to file a form that relates to interests in or transactions with foreign trusts, timely.
Never assume that the outcome planned for under the rules of your old home country will remain unaffected by an international move involving the U.S.
For further details on this topic see "Wills
and Trusts for the International Family"
The material provided in this
website is for informational purposes only and does not
constitute tax or legal advice. Such advice can only be
provided with full knowledge of your particular facts and
circumstances. Tax Law, Pensions, IRS, UK, US,
United States
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