Succession Planning for International Families

Bureaucracy Without Pain, in 2,700-ish words

Written by a cross-border tax advisor who has spent two decades translating legal double-speak into plain English—so you can spend less time reading statutes and more time choosing where the family meets for New Year’s Eve.

Why Bother?

“I’m healthy, my kids are tiny, the yacht’s insured—do I really need a plan?”

Short answer: yes. Long answer: absolutely, unless you want your heirs learning Latin phrases like per stirpes while a probate judge in a country you’ve never visited decides who gets the Phuket condo.

Succession planning is simply the art of moving assets (and sometimes liabilities) from one generation to the next with minimal:

• Tax leakage
• Legal uncertainty
• Family infighting
• Administrative delay

If your life ticks at least two of the following boxes, keep reading:

• Multiple passports or residencies
• Assets in two or more countries (e.g., French apartment, Delaware LLC, Thai share portfolio)
• Children or heirs who might move countries before you’re done reading this sentence
• Use of structures such as trusts, foundations, or a freelancer-friendly offshore company

Those moving parts create “conflict-of-law” risks. A Dutch notary, a Singaporean trust officer, and an IRS examiner may all claim jurisdiction over the same estate. Good planning makes them play nicely together—or at least queue in an orderly fashion.

The 7-Step Succession Framework

(aka Bureaucracy Without Pain)

Below is the workflow I use with globally mobile families. No legalese, no mystique—just sequential tasks.

1. Map Your Personal Footprint

Document, in one tidy spreadsheet, your:

• Citizenship(s) & tax residency status
• Visa or residency permits (from Golden Visas to a Costa Rica Rentista residency)
• Marital status under each jurisdiction’s eyes
• Number and ages of heirs, including step-children or dependents
• Charitable intentions

Why it matters: succession law often follows nationality or habitual residence, while tax law follows residency or domicile. Untangling the difference after death involves court affidavits and genealogists—costly and public.

2. Inventory Global Assets (and Debts)

Include:

• Real estate deeds
• Bank, brokerage, and crypto wallets
• Operating companies, limited partnerships, trusts
• Intellectual property (royalties, patents, NFTs of you surfing)
• Liabilities: mortgages, shareholder loans, personal guarantees

Tip: assign each asset to the jurisdiction that can legally seize or tax it. Your UK ISA might be physically custodied in Germany; HMRC still wields taxing rights.

3. Identify Governing Laws

Match each asset to:

1. Succession law (who inherits, forced-heirship rules, marriage regimes)
2. Estate/inheritance tax law
3. Gift tax and capital-gains triggers on death

Use colour coding—red for hostile (e.g., 40 % estate tax, forced heirship), green for neutral, yellow for uncertain.

Pro tip: If you hold UAE real estate, Sharia principles apply by default even if you’re not Muslim—unless you registered a DIFC will. Small print, big impact.

4. Select Planning Instruments

Common tools:

• Multijurisdictional will (one “master” plus local “pour-over” wills)
• Revocable or irrevocable trusts
• Private foundations or Stiftung
• Family holding company or partnership
• Life insurance wrappers
• Prenuptial and postnuptial agreements

Match tool to goal:
• Asset protection?—irrevocable trust.
• Probate speed?—joint tenancy or pay-on-death designation.
• Forced-heirship workaround?—foundation in Liechtenstein or Panama.

5. Model the Tax Outcomes

Fire up Excel or your favourite tax engine. Inputs:

• Market values (today + conservative growth rate)
• Jurisdictional tax brackets, credits, and double-tax treaties
• Anticipated currency shifts (JPY inheritance tax is calculated in yen, then converted)
• Administration costs (trustee fees, legal drafting)

Result: a side-by-side cost of dying with versus without the plan. If the delta is six figures, action yesterday wouldn’t have been too soon.

6. Execute & Document

Sequence matters:

1. Draft wills after creating trusts or foundations, so wills can reference them.
2. Move title of assets into chosen vehicles. Half-finished paperwork creates orphan assets.
3. Notarise and apostille where required.
4. Store originals in two jurisdictions; lodge copies with executors and trustees.
5. Update beneficiary designations on insurance and banks—often overlooked.

7. Maintain & Review

Life events demand updates:

• Marriage, divorce, new child
• Moving tax residency
• Exiting or entering business ventures
• Legislative changes (e.g., Spain’s “exit tax” or U.S. corporate transparency rules)

Set an annual reminder. I bake it into clients’ year-end tax checklist— as crucial as reconciling crypto gains.

Costs & Timelines at a Glance

Below are realistic, mid-market numbers for an international family of four with assets in three regions.

Pull-quote: “Estate planning is expensive—but probate across five countries is much more expensive, and infinitely more public.”

The 8 Classic Mistakes I Still See (So You Don’t Repeat Them)

1. Drafting a single will that accidentally revokes your foreign wills.
2. Assuming a trust created in Country A shields real estate in Country B from probate—many civil-law courts ignore trusts.
3. Holding crypto on an exchange without a legally recognised transfer-on-death mechanism (your heirs will play ‘guess the seed phrase’).
4. Ignoring forced-heirship: France, Portugal, and the UAE allocate fixed shares to children and spouses—your “disinherit my ex” clause won’t override.
5. Forgetting the family business’ shareholder agreement. Succession planning stops cold if the buy-sell clause forces liquidation.
6. Keeping accounts in nominee names no one recognises. Privacy is good; opacity creates orphan assets.
7. Moving to a new country on a digital-nomad visa without checking exit-tax rules in the old country.
8. Letting the perfect plan block the good plan—most judges prefer a flawed but signed document over none.

Real-World Snapshot

A family I advised last year—Swiss father, Brazilian mother, two kids born in Singapore—held:

• Two apartments: Zurich & Lisbon
• A SaaS company via Delaware C-corp
• A Costa Rica beach house (purchased during their Rentista phase)
• 12 BTC in cold storage

Problems identified:

1. Switzerland has no forced-heirship if you are not resident at death; Portugal does.
2. Delaware probate is public; the SaaS cap table would reveal itself.
3. Costa Rican probate is slow (9-18 months) and Spanish-language only.

Solution implemented:

• Put SaaS shares inside a Wyoming trust; trust interests referenced in a Singapore will.
• Created a Portuguese foundation to own the Lisbon apartment, bypassing forced-heirship.
• Registered a DIFC will for Dubai bank accounts (yes, they opened one for USD diversification).
• Engraved multisig hardware wallets’ recovery instructions into stainless plates, stored in Zurich and Singapore vaults.

Outcome: projected estate tax dropped from 14 % to <3 %; probate timelines under six months. Cost: ≈USD 38k. Savings: USD 800k+ and family harmony.

Glossary (Because Jargon Sneaks In)

• Forced-heirship – statutory rule allocating fixed shares of your estate to spouse/children.
• Probate – court process validating a will and transferring assets.
• Domicile – long-term home for succession tax purposes, distinct from tax residency.
• Pour-over will – will that transfers (“pours”) assets into an existing trust at death.
• Letters of Administration – court order appointing executor when no valid will exists.

Quick-Fire FAQs

Is a revocable living trust recognised worldwide?
No. Common-law jurisdictions nod politely; many civil-law courts see it as a contract at best, or ignore it. Supplement with local wills or corporate wrappers.

Can I name minor children as beneficiaries?
Yes, but assets sit in guardianship until they reach majority—unless you use a trust or foundation to drip-feed distributions.

What if I hold second citizenship via investment?
Succession law often follows citizenship in civil-law countries. Renouncing late in life can trigger exit taxes. Factor it in.

Do digital assets need special treatment?
Absolutely. Add a memorandum of instructions outside the will (to avoid public disclosure) and ensure executors are tech-literate.

Final Thoughts

Cross-border succession planning is not about morbid contemplation; it is a logistical gift to your heirs. The bureaucracy can be painless—provided you tackle it before life throws its curveballs.

Ready to see how your personal footprint stacks up? Spend three minutes with BorderPilot and generate a free, data-driven relocation (and succession) plan tailored to your jurisdictions. Your future self—and your heirs—will thank you.