Where an estate has assets in multiple jurisdictions, a number of different court authorities or notarial declarations may be required to attend to the administration of those assets.

When attending to foreign assets, you may find that you have to comply with complicated foreign laws and taxes, and there may also be a language barrier. We are familiar with the requirements of foreign courts and asset companies throughout the world.  We are often able to attend to the administration of a foreign asset directly from our office or refer you to one of our contacts who can.

If an asset is located outside of the UK in a Commonwealth country, we can assist with the reseal application or refer you to one of our contacts.

We regularly assist with reseal application in South Africa, Australia, New Zealand, Canada, Malaysia and a number of other Commonwealth countries.  For more information on resealing, please click here.

If you’re dealing with an estate that has assets located in the islands of Jersey, Guernsey and the Isle of Man, we’re well equipped to assist with the separate probate application that may be required and with the administration of the assets located in these islands.

Please click here to view our dedicated webpage for these islands.

A “fast-track” procedure applies for estates where the deceased passed away domiciled in England & Wales, Scotland, Northern Ireland, Guernsey or the Isle of Man (British Isles).

If you are dealing with the estate where the deceased passed away domiciled within the British Isles and a Jersey grant is required, please feel free to get in touch.  We would be happy to schedule the documents that are required for the application and provide a quote for your approval.

Many people own assets located in North America for a variety of reasons. For example, it’s quite common in the UK for shareholders to find themselves with shares in US companies due to buyouts or mergers with UK companies.   People may also have acquired assets in North America through work, pleasure or simply for investment purposes.

We regularly assist our clients with administering shares, bank accounts and investment funds located in the US and Canada.  We can also assist with unclaimed property and escheated assets in both the US and Canada.

If you’re responsible for dealing with an estate involving North American shares, you will usually be asked to provide a medallion signature guarantee.

The medallion is a statutory requirement when managing the movement of shares in North America and they act to limit the liability to transfer agents and to safeguard against forged signatures.

If you find yourself in a position where you require a medallion, we can help. We’re particularly proud to say that our firm was the first law firm outside of the US to be enrolled as a provider of medallions.

We can offer the choice of two services for our clients:

1. We can provide the medallion only; or
2. We can deal with the full administration of the asset that requires the medallion and we include the medallion for no additional charge.

Estates with assets located in North America can present some complex procedures. For example, if the assets are located in the US and are valued above $60,000, the asset holder may request estate tax clearance (federal transfer certificates) from the Internal Revenue Service.

We’ve developed a particular expertise in US estate tax reporting, which can be particularly onerous for those estates where the deceased passed away domiciled outside of the US and a non-US citizen.

Depending on the nature and value of assets located in the UK, it is possible that a UK inheritance tax account may be required and tax may need to be paid.

We have a wealth of experience in dealing with foreign domiciled estates that have assets located in the UK.  We can advise on what exemptions may be available and whether unilateral relief or a double taxation agreement may help to mitigate the UK tax position.

In the international setting, one of the most fundamental parts of dealing with an estate is analysing the domicile.  This can determine which law will govern the succession to certain assets.

The domicile will also have a big impact on the UK inheritance tax position.  We can advise on whether an estate is caught by our “deemed” domicile rules, which can artificially impose a fiscal domicile in the UK for inheritance tax purposes.   If an estate is caught by these rules, this could result in an assessment for UK inheritance tax on the worldwide assets.

Many of the estates that we work with have assets located in European countries.  The most common examples for our team include France, Spain, Italy, the Netherlands, Germany, Belgium, Switzerland and Luxembourg.

If you need advice on an asset located in Europe, you’re welcome to contact us to see how we can help or refer you to a local professional who can.