Cross-Border Estate Planning

Assets in different countries are governed by different succession rules. Some countries apply the law of the deceased's nationality, others the law of where the asset is — and Vietnam applies its own rules to land here regardless of anything else.

Wise Counsel coordinates estate planning across Vietnam and your home jurisdiction so that assets pass as intended in both.

What we help with

• Mapping which country's succession law applies to each asset
• Advising on the position of Vietnamese real estate and land use rights
• Coordinating wills across jurisdictions so they do not revoke each other
• Advising on forced heirship rules that may override your wishes
• Advising on the tax treatment of the estate in each country
• Structuring lifetime transfers as an alternative to inheritance
• Working with your advisers abroad to keep the plan consistent
• Reviewing the plan when you move country or acquire new assets

A later will can unintentionally revoke an earlier one in another country. That is the most common failure in cross-border planning, and it is easily avoided.