International Estate & Tax Planning

Tailored legal strategies for individuals and families with cross-border lives — coordinating U.S. estate and tax planning with the complexities of foreign assets, international beneficiaries, and multi-jurisdictional wealth.

"For non-U.S. citizens, the U.S. estate tax exemption drops dramatically to just $60,000 — compared to over $15 million for U.S. citizens. Proactive planning is essential for foreign nationals with any U.S. presence."

Services Include

  • Cross-Border Estate Planning

  • Qualified Domestic Trusts (QDOTs)

  • Foreign National Estate Strategies

  • Pre-Immigration Tax Planning

  • Pre-Expatriation Planning

  • Foreign Trust Compliance

  • Treaty-Based Tax Planning

  • Multi-Jurisdiction Will Coordination

  • Cross-Border Gift & Inheritance Reporting

  • Foreign Asset Disclosure & Planning

Frequently Asked Questions

  • Yes. Non-resident aliens are subject to U.S. estate tax on U.S. situs assets — such as U.S. real estate and U.S. stocks — but only receive a $60,000 exemption (compared to over $15 million for U.S. citizens). Careful pre-purchase or pre-immigration planning can significantly reduce this exposure.

  • A QDOT is a special trust that allows a U.S. citizen spouse to leave assets to a non-U.S. citizen surviving spouse while still qualifying for the unlimited marital deduction. Without a QDOT, assets passing to a non-citizen spouse do not qualify for the marital deduction and may be subject to immediate estate tax.

  • In many cases, yes. While an international will may be recognized in some countries, it is often more efficient and reliable to have jurisdiction-specific wills for assets located in different countries. We help coordinate your documents to avoid conflicts and ensure your wishes are honored globally.

  • U.S. persons who receive gifts or inheritances from foreign persons above certain thresholds are required to report these receipts to the IRS (Form 3520). Failure to report can result in significant penalties. We assist clients in ensuring proper reporting and understanding the U.S. tax treatment of foreign inheritances.

International Planning Starts Here

Our attorneys work seamlessly across borders to protect globally held wealth.

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Planning for Families Without Borders

International families face estate and tax planning challenges that go far beyond the scope of a domestic practice. U.S. citizens living abroad, foreign nationals owning U.S. assets, and families with beneficiaries or assets in multiple countries must navigate overlapping — and sometimes conflicting — legal regimes.

Our attorneys bring deep knowledge of U.S. international tax law and work in coordination with foreign counsel to develop integrated estate plans that protect wealth, minimize tax, and avoid costly mistakes at every level.

Who We Serve

Our international estate and tax planning practice is designed for:

  • U.S. citizens and long-term residents living abroad

  • Non-resident aliens (NRAs) with U.S. situs assets

  • Dual citizens and individuals with complex immigration status

  • Families with children or beneficiaries in foreign countries

  • Foreign nationals planning to acquire U.S. real estate or investments

  • Individuals considering U.S. expatriation or citizenship renunciation

  • Families receiving or making cross-border gifts and inheritances

Key Areas of Focus

International estate and tax planning requires attention to a wide range of issues, including:

  • U.S. estate and gift tax treatment of foreign nationals and non-resident aliens

  • Treaty-based planning to mitigate double estate taxation

  • Qualified Domestic Trusts (QDOTs) for non-U.S. citizen spouses

  • Foreign Trust planning, reporting, and compliance (Forms 3520, 3520-A)

  • Pre-immigration and pre-expatriation planning

  • U.S. estate planning for cross-border families with foreign assets

  • Coordination of wills and powers of attorney across jurisdictions

  • Inheritance planning for beneficiaries in foreign countries

Coordinating Across Jurisdictions

Cross-border estate planning requires coordination between U.S. law and the laws of the other countries involved. Each jurisdiction may have its own rules regarding succession, forced heirship, marital property, and inheritance taxes. Without careful planning, a family's assets could be subject to tax in multiple countries simultaneously, or distributed in ways that conflict with the decedent's wishes.

We work with trusted networks of foreign counsel in key jurisdictions to ensure your plan is coherent, compliant, and optimized across borders.