Succession Navigator

Succession: UAE → United States

Scenario: the testator is a citizen and resident of the first country; the heir resides in the second. No asset locations are specified, so this is not a calculation for a particular estate.

Recorded context for your selection

Selected context labels: ae, us

Testator

UAE

Supplied label only; actual residence, governing law and personal entitlement are undetermined.

Heir

United States

Supplied label only; actual residence, governing law and personal entitlement are undetermined.

Law

Applicable-law context

  • ae: What are the recorded scope of Regulation (EU) No 650/2012, applicable-law connecting factors, choice-of-law conditions and transitional provisions for this country? — Recorded rules are available; their applicability to this case has not been established. The United Arab Emirates does not participate in Regulation (EU) No 650/2012; it does not establish local jurisdiction or ECS issuance there. A participating forum may nevertheless designate its law under the Regulation’s universal conflict rules, without making that country a participant. For successions of persons dying on or after 17 August 2015, a participating forum generally applies the law of the deceased’s habitual residence at death to the succession as a whole. Article 21(2) is exceptional: all the circumstances must clearly show that, at death, the deceased was manifestly more closely connected with another State. Article 22 permits a choice for the succession as a whole of the law of any State of nationality at choice or death, including where there are multiple nationalities and a non-EU State. The choice must be express in a declaration in the form of a disposition of property upon death or demonstrated by its terms; the chosen law governs the act’s substantive validity, and modification or revocation must meet the form requirements for modifying or revoking a disposition. Under Article 30, special restrictions for immovable property, enterprises or special asset categories on economic, family or social grounds apply under the law of their location only insofar as that law makes them applicable regardless of the law governing the succession. Article 34 permits third-State conflict rules to refer to the law of a participating State or another third State which would apply its own law; renvoi is excluded for Articles 21(2), 22, 27, 28(b) and 30. Article 35 permits refusal to apply a provision only where its application is manifestly incompatible with the forum’s public policy. Article 83(2) preserves a pre-17 August 2015 choice if it meets Chapter III or the conflict rules then in force in the State of habitual residence or any State of nationality of the deceased. Article 83(3) separately preserves the admissibility, substantive validity and form of an earlier disposition under Chapter III or the conflict rules in force when the disposition was made in the State of habitual residence, any State of nationality of the deceased, or the participating State whose authority deals with the succession. Under Article 83(4), an earlier disposition made in accordance with a law that could have been chosen under the Regulation deems that law chosen for the succession. — The disposition’s own formal and substantive validity require separate review. The law determined under Articles 21–22 governs, among other matters, beneficiaries’ shares, reserved shares and restoration or accounting for gifts when calculating shares (Article 23(2)); a choice is no promise of exemption from those rules. Tax, matrimonial property regimes, the nature of rights in rem and registration of rights are outside the Regulation. Written dispositions have alternative form connecting factors under Article 27, subject to Article 75(1): States party to the 1961 Hague Convention continue to apply it instead of Article 27 for wills and joint wills. Other conventions and the Regulation’s precedence between participating States are assessed under Article 75. This records the framework, not the law of a particular estate; habitual residence and nationalities, death and disposition dates, forum, assets, the particular legal system, testamentary wording, treaties, mandatory rules, procedure and registration remain unestablished. — «Article 1 Scope 1.   This Regulation shall apply to succession to the estates of deceased persons. It shall not apply to revenue, customs or administrative matters. 2.   The following shall be excluded from the scope of this Regulation: (a)  the status of natural persons, as well as family relationships and relationships deemed by the law applicable to such relationships to have comparable effects; (b)  the legal capacity of natural persons, without prejudice to point (c) of Article 23(2) and to Article 26; (c)  questions relating to the disappearance, absence or presumed death of a natural person; (d)  questions relating to matrimonial property regimes and property regimes of relationships deemed by the law applicable to such relationships to have comparable effects to marriage; (e)  maintenance obligations other than those arising by reason of death; (f)  the formal validity of dispositions of property upon death made orally; (g)  property rights, interests and assets created or transferred otherwise than by succession, for instance by way of gifts, joint ownership with a right of survivorship, pension plans, insurance contracts and arrangements of a similar nature, without prejudice to point (i) of Article 23(2); (h)  questions governed by the law of companies and other bodies, corporate or unincorporated, such as clauses in the memoranda of association and articles of association of companies and other bodies, corporate or unincorporated, which determine what will happen to the shares upon the death of the members; (i)  the dissolution, extinction and merger of companies and other bodies, corporate or unincorporated; (j)  the creation, administration and dissolution of trusts; (k)  the nature of rights in rem; and (l)  any recording in a register of rights in immovable or movable property, including the legal requirements for such recording, and the effects of recording or failing to record such rights in a register.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 1; current-official-snapshot-utf8:1487:3717 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 20 Universal application Any law specified by this Regulation shall be applied whether or not it is the law of a Member State.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 20; current-official-snapshot-utf8:17707:17853 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 21 General rule 1.   Unless otherwise provided for in this Regulation, the law applicable to the succession as a whole shall be the law of the State in which the deceased had his habitual residence at the time of death. 2.   Where, by way of exception, it is clear from all the circumstances of the case that, at the time of death, the deceased was manifestly more closely connected with a State other than the State whose law would be applicable under paragraph 1, the law applicable to the succession shall be the law of that other State.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 21; current-official-snapshot-utf8:17863:18439 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 22 Choice of law 1.   A person may choose as the law to govern his succession as a whole the law of the State whose nationality he possesses at the time of making the choice or at the time of death. A person possessing multiple nationalities may choose the law of any of the States whose nationality he possesses at the time of making the choice or at the time of death. 2.   The choice shall be made expressly in a declaration in the form of a disposition of property upon death or shall be demonstrated by the terms of such a disposition. 3.   The substantive validity of the act whereby the choice of law was made shall be governed by the chosen law. 4.   Any modification or revocation of the choice of law shall meet the requirements as to form for the modification or revocation of a disposition of property upon death.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 22; current-official-snapshot-utf8:18452:19338 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 23 The scope of the applicable law 1.   The law determined pursuant to Article 21 or Article 22 shall govern the succession as a whole. 2.   That law shall govern in particular: (a)  the causes, time and place of the opening of the succession; (b)  the determination of the beneficiaries, of their respective shares and of the obligations which may be imposed on them by the deceased, and the determination of other succession rights, including the succession rights of the surviving spouse or partner; (c)  the capacity to inherit; (d)  disinheritance and disqualification by conduct; (e)  the transfer to the heirs and, as the case may be, to the legatees of the assets, rights and obligations forming part of the estate, including the conditions and effects of the acceptance or waiver of the succession or of a legacy; (f)  the powers of the heirs, the executors of the wills and other administrators of the estate, in particular as regards the sale of property and the payment of creditors, without prejudice to the powers referred to in Article 29(2) and (3); (g)  liability for the debts under the succession; (h)  the disposable part of the estate, the reserved shares and other restrictions on the disposal of property upon death as well as claims which persons close to the deceased may have against the estate or the heirs; (i)  any obligation to restore or account for gifts, advancements or legacies when determining the shares of the different beneficiaries; and (j)  the sharing-out of the estate.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 23; current-official-snapshot-utf8:19351:21105 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 27 Formal validity of dispositions of property upon death made in writing 1.   A disposition of property upon death made in writing shall be valid as regards form if its form complies with the law: (a)  of the State in which the disposition was made or the agreement as to succession concluded; (b)  of a State whose nationality the testator or at least one of the persons whose succession is concerned by an agreement as to succession possessed, either at the time when the disposition was made or the agreement concluded, or at the time of death; (c)  of a State in which the testator or at least one of the persons whose succession is concerned by an agreement as to succession had his domicile, either at the time when the disposition was made or the agreement concluded, or at the time of death; (d)  of the State in which the testator or at least one of the persons whose succession is concerned by an agreement as to succession had his habitual residence, either at the time when the disposition was made or the agreement concluded, or at the time of death; or (e)  in so far as immovable property is concerned, of the State in which that property is located. The determination of the question whether or not the testator or any person whose succession is concerned by the agreement as to succession had his domicile in a particular State shall be governed by the law of that State. 2.   Paragraph 1 shall also apply to dispositions of property upon death modifying or revoking an earlier disposition. The modification or revocation shall also be valid as regards form if it complies with any one of the laws according to the terms of which, under paragraph 1, the disposition of property upon death which has been modified or revoked was valid. 3.   For the purposes of this Article, any provision of law which limits the permitted forms of dispositions of property upon death by reference to the age, nationality or other personal conditions of the testator or of the persons whose succession is concerned by an agreement as to succession shall be deemed to pertain to matters of form. The same rule shall apply to the qualifications to be possessed by any witnesses required for the validity of a disposition of property upon death.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 27; current-official-snapshot-utf8:24919:27321 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 30 Special rules imposing restrictions concerning or affecting the succession in respect of certain assets Where the law of the State in which certain immovable property, certain enterprises or other special categories of assets are located contains special rules which, for economic, family or social considerations, impose restrictions concerning or affecting the succession in respect of those assets, those special rules shall apply to the succession in so far as, under the law of that State, they are applicable irrespective of the law applicable to the succession.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 30; current-official-snapshot-utf8:31365:31956 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 34 Renvoi 1.   The application of the law of any third State specified by this Regulation shall mean the application of the rules of law in force in that State, including its rules of private international law in so far as those rules make a renvoi: (a)  to the law of a Member State; or (b)  to the law of another third State which would apply its own law. 2.   No renvoi shall apply with respect to the laws referred to in Article 21(2), Article 22, Article 27, point (b) of Article 28 and Article 30.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 34; current-official-snapshot-utf8:33531:34117 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 35 Public policy (ordre public) The application of a provision of the law of any State specified by this Regulation may be refused only if such application is manifestly incompatible with the public policy (ordre public) of the forum.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 35; current-official-snapshot-utf8:34130:34384 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 75 Relationship with existing international conventions 1.   This Regulation shall not affect the application of international conventions to which one or more Member States are party at the time of adoption of this Regulation and which concern matters covered by this Regulation. In particular, Member States which are Contracting Parties to the Hague Convention of 5 October 1961 on the Conflicts of Laws Relating to the Form of Testamentary Dispositions shall continue to apply the provisions of that Convention instead of Article 27 of this Regulation with regard to the formal validity of wills and joint wills. 2.   Notwithstanding paragraph 1, this Regulation shall, as between Member States, take precedence over conventions concluded exclusively between two or more of them in so far as such conventions concern matters governed by this Regulation. 3.   This Regulation shall not preclude the application of the Convention of 19 November 1934 between Denmark, Finland, Iceland, Norway and Sweden comprising private international law provisions on succession, wills and estate administration, as revised by the intergovernmental agreement between those States of 1 June 2012, by the Member States which are parties thereto, in so far as it provides for: (a)  rules on the procedural aspects of estate administration as defined by the Convention and assistance in that regard by the authorities of the States Contracting Parties to the Convention; and (b)  simplified and more expeditious procedures for the recognition and enforcement of decisions in matters of succession.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 75; current-official-snapshot-utf8:68267:69936 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 83 Transitional provisions 1.   This Regulation shall apply to the succession of persons who die on or after 17 August 2015. 2.   Where the deceased had chosen the law applicable to his succession prior to 17 August 2015, that choice shall be valid if it meets the conditions laid down in Chapter III or if it is valid in application of the rules of private international law which were in force, at the time the choice was made, in the State in which the deceased had his habitual residence or in any of the States whose nationality he possessed. 3.   A disposition of property upon death made prior to 17 August 2015 shall be admissible and valid in substantive terms and as regards form if it meets the conditions laid down in Chapter III or if it is admissible and valid in substantive terms and as regards form in application of the rules of private international law which were in force, at the time the disposition was made, in the State in which the deceased had his habitual residence or in any of the States whose nationality he possessed or in the Member State of the authority dealing with the succession. 4.   If a disposition of property upon death was made prior to 17 August 2015 in accordance with the law which the deceased could have chosen in accordance with this Regulation, that law shall be deemed to have been chosen as the law applicable to the succession.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 83; current-official-snapshot-utf8:74702:76141 — Source date: 2012-07-04 — Verified: 2026-10-17 — «These new rules apply to the succession of those who die on or after 17 August 2015. The Regulation ensures that a cross-border succession is treated coherently, under a single law and by one single authority.» — European e-Justice: succession general information — https://e-justice.europa.eu/topics/family-matters-inheritance/inheritance/succession_en — succession_1; current-official-snapshot-utf8:1695:1904 — Verified: 2026-10-17 — «Pages (27) RSS Showing results 1 to 20 Austria EU Member State since 1995, Euro area member since 1999, Schengen area member since 1997 and more about Austria’s participation in the EU. Belgium EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Belgium’s participation in the EU. Bulgaria EU Member State since 2007, Euro area member since 2026, Schengen area member since 2024 and more about Bulgaria's participation in the EU. Croatia EU Member State since 2013, Euro area member since 2023, Schengen area member since 2023 and more about Croatia’s participation in the EU. Cyprus EU Member State since 2004, Euro area member since 2008, and more about Cyprus’s participation in the EU. Czechia EU Member State since 2004, Schengen area member since 2007 and more about Czechia’s participation in the EU. Denmark EU Member State since 1973, Schengen area member since 2001 and more about Denmark’s participation in the EU. Estonia EU Member State since 2004, Euro area member since 2011, Schengen area member since 2007 and more about Estonia’s participation in the EU. Finland EU Member State since 1995, Euro area member since 1999, Schengen area member since 2001 and more about Finland’s participation in the EU. France EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about France’s participation in the EU. Germany EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Germany’s participation in the EU. Greece EU Member State since 1981, Euro area member since 2001, Schengen area member since 2000 and more about Greece’s participation in the EU. Hungary EU Member State since 2004, Schengen area member since 2007 and more about Hungary’s participation in the EU. Ireland EU Member State since 1973, Euro area member since 1999 and more about Ireland’s participation in the EU. Italy EU Member State since 1958, Euro area member since 1999, Schengen area member since 1997 and more about Italy’s participation in the EU. Latvia EU Member State since 2004, Euro area member since 2014, Schengen area member since 2007 and more about Latvia’s participation in the EU. Lithuania EU Member State since 2004, Euro area member since 2015, Schengen area member since 2007 and more about Lithuania’s participation in the EU. Luxembourg EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Luxembourg’s participation in the EU. Malta EU Member State since 2004, Euro area member since 2008, Schengen area member since 2007 and more about Malta’s participation in the EU. Netherlands EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Dutch participation in the EU. 1 Page 1 2 Next » — EU countries — official list page 1 of 2 — https://european-union.europa.eu/principles-countries-history/eu-countries_en — members_complete_page1; current-official-snapshot-utf8:1980:4855 — Verified: 2026-10-17 — «Pages (27) RSS Showing results 20 to 27 Poland EU Member State since 2004, Schengen area member since 2007 and more about Poland’s participation in the EU. Portugal EU Member State since 1986, Euro area member since 1999, Schengen area member since 1995 and more about Portugal’s participation in the EU. Romania EU Member State since 2007, Schengen area member since 2024 and more about Romania’s participation in the EU. Slovakia EU Member State since 2004, Euro area member since 2009, Schengen area member since 2007 and more about Slovakia’s participation in the EU. Slovenia EU Member State since 2004, Euro area and Schengen area member since 2007 and more about Slovenia’s participation in the EU. Spain EU Member State since 1986, Euro area member since 1999, Schengen area member since 1995 and more about Spain’s participation in the EU. Sweden EU Member State since 1995, Schengen area member since 2001 and more about Sweden’s participation in the EU. Previous 1 2 Page 2 » — EU countries — official list page 2 of 2 — https://european-union.europa.eu/principles-countries-history/eu-countries_en?page=1 — members_complete_page2; current-official-snapshot-utf8:1980:2979 — Verified: 2026-10-17 — «The Regulation applies between all Member States except Denmark and Ireland. The Regulation also introduces a European Certificate of Succession (ECS).» — European e-Justice: European Certificate of Succession — https://online-forms.e-justice.europa.eu/online-forms/european-certificate-succession_en — ecs_1; current-official-snapshot-utf8:971:1122 — Verified: 2026-10-17 — Recorded regulation context only; personal applicability and governing law: unknown.
  • ae / succ.law.connecting: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.law.scission: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.law.choice: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.law.connecting: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.law.scission: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.law.choice: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]

Reserved interests

Reserved-share context

  • ae / succ.forced.exists: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.circle: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.children: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.spouse: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.fraction: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.form: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.clawback: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.lookback: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.waiver: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.provision: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.prevails: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.forced.aggregate.share: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.exists: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.circle: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.children: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.spouse: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.fraction: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.form: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.clawback: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.lookback: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.waiver: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.provision: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.prevails: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.forced.aggregate.share: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]

Tax

Whole country tax context

  • ae / succ.tax.country_context: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • Record object: us What is the general inheritance tax context in this jurisdiction? Recorded rules are available; their applicability to this case has not been established. Recorded provision 1 US federal estate tax uses a progressive schedule with a top 40% marginal rate above $1 million of the relevant tax-computation amount. For a decedent who at death was neither US domiciled nor a US citizen for estate-tax purposes, the executor must file Form 706-NA if death-date US-situs assets, the specified gift-tax exemption for gifts made from 9 September through 31 December 1976, and adjusted taxable gifts after 31 December 1976 together exceed $60,000. The ordinary maximum unified credit of $13,000 corresponds to tax on the first $60,000 under the base schedule; treaties, US-territory and expatriation rules and other conditions can change the calculation. Stock issued by a US-law corporation is generally US situs. These are decedent-estate rules, not a personal allowance for a foreign heir. This is general source context. Estate assets, death date, decedent and heir status, kinship, reliefs, treaties and local rules require review; no personal tax is calculated here. not in the sources primary source cited, quotation verified on 2026-10-18 Source evidence is within its recorded review window. The source check is confirmed; it is not a legal applicability conclusion. Record checked: 2026-10-18 Source evidence checked: 2026-10-18T05:53:33.454Z Scheduled record recheck: 2027-10-18 Scheduled source recheck: 2027-10-18T05:53:33.454Z Sources: 1, 2, 3, 4, 5, 6 Sources and quotations [1] To the taxable estate, add the value of lifetime taxable gifts, beginning with gifts made in 1977, of tangible or intangible property located in the United States that was transferred directly or indirectly, and not included in the gross estate. If the date of death value of the decedent’s U.S.-situated assets, together with the gift tax specific exemption and the amount of the adjusted taxable gifts, exceeds the filing threshold of $60,000, the executor must file a Form 706-NA for the decedent’s estate. The filing threshold for Form 706-NA is not indexed for inflation. See the Instructions for Form 706-NA for additional information on the gift tax specific exemption and the amount of adjusted taxable gifts. The Form 706-NA, United States Estate (and Generation-Skipping Transfer) Tax Return Estate of nonresident not a citizen of the United States , if required, must be filed within 9 months after the date of death unless an extension of time to file was granted. C6 tax context us_nrnc https://www.irs.gov/businesses/small-businesses-self-employed/estate-tax-for-nonresidents-not-citizens-of-the-united-states Locator: addressed_visible_projection:filing threshold of $60,000 Source date: — Checked: 2026-10-18 [2] For estate tax purposes, a citizen of a U.S. possession is not a U.S. citizen. U.S.-situated assets that are subject to estate tax include, for example: Real estate located in the U.S., Tangible personal property (excluding some art), and Stock of corporations organized in or under U.S. law, even if the nonresident held the certificates abroad or registered the certificates in the name of a nominee. Examples of property treated as situated outside the U.S., and therefore not subject to the U.S. estate tax, include certain deposits and debt obligations described in Section 871(g)-(i), bank accounts deposited with a foreign branch of a domestic commercial banking business, and proceeds of life insurance on the life of a nonresident who is not a U.S. citizen. C6 tax context us_situs https://www.irs.gov/individuals/international-taxpayers/some-nonresidents-with-us-assets-must-file-estate-tax-returns Locator: IRS US-situs examples and complete concluding excluded-property sentence Source date: — Checked: 2026-10-18 [3] Department of the Treasury Internal Revenue Service Center Kansas City, MO 64999 Part II—Tax Computation Lines 4 and 5 To determine the tentative tax on the amount on line 2 (to be entered on line 5) and the tentative tax on the amount on line 3 (to be entered on line 4), use Table A—Unified Rate Schedule in the version of the Instructions for Form 706 that corresponds to the decedent's date of death. Line 7 Enter the unified credit. The unified credit is allowed for the smaller of the line 6 amount or the maximum unified credit. In general, the maximum unified credit is $13,000. For a citizen of a U.S. territory (see section 2209), the maximum unified credit is the greater of: $13,000, or The product of $46,800 times a fraction. The numerator of the fraction is the part of the gross estate located in the United States (line 1 of Part IV), and the denominator is the entire gross estate wherever located (line 3 of Part IV). If the unified credit is affected by a treaty, see section 2102(b)(3)(A). C6 tax context us_instr_na https://www.irs.gov/instructions/i706na Locator: addressed_visible_projection:maximum unified credit is $13,000 Source date: — Checked: 2026-10-18 [4] Who Must File The executor must file Form 706-NA if the date of death value of the decedent’s U.S.-situated assets, together with the gift tax specific exemption and the amount of adjusted taxable gifts, exceeds the filing threshold of $60,000. The gift tax specific exemption refers to the amount allowed for gifts made by the decedent between September 9, 1976, and December 31, 1976, inclusive. The amount of adjusted taxable gifts refers to the amount of adjusted taxable gifts made by the decedent after December 31, 1976. C6 tax context us_instr_na https://www.irs.gov/instructions/i706na Locator: Form706-NA complete filing formula and historic gift definitions Source date: — Checked: 2026-10-18 [5] Definitions The following definitions apply in these instructions. United States. The United States means the 50 states and the District of Columbia. Domicile. For estate tax purposes, a person acquires domicile in a place by living there, for even a brief period of time, with no definite present intention of later moving. See Regulations section 20.0-1 for more information. Nonresident not a citizen of the United States (NRNC). For estate tax purposes, a decedent is a nonresident not a citizen of the United States (NRNC) if the decedent is neither domiciled in nor a citizen of the United States at the time of death. A decedent who acquired U.S. citizenship solely by reason of being a citizen of a U.S. territory or by reason of birth or residence within a U.S. territory is not treated as a U.S. citizen. Note. A decedent may be a U.S. resident for income tax purposes yet be considered a nonresident for estate tax purposes. Long-term U.S. resident. A long-term U.S. resident is an individual (other than a U.S. citizen) who has been a lawful permanent resident of the United States (green card holder) for income tax purposes in at least 8 of the last 15 tax years ending with the tax year in which U.S. income tax residency is terminated. For more information, see section 877(e). For information regarding the definition of lawful permanent resident, including circumstances in which the lawful permanent resident status of a treaty resident is considered terminated, see the Instructions for Form 8854, Initial and Annual Expatriation Statement. Executor. An executor is the personal representative, executor, executrix, administrator, or administratrix of the decedent’s estate. If no executor is appointed, qualified, and acting in the United States, every person in actual or constructive possession of any of the decedent's property is considered an executor and must file a return. If more than one person must file, it is preferable that they join in filing one complete return. Otherwise, each person must file as complete a return as possible, including a full description of the property and each person's name who holds an interest in it. Executors must provide documentation proving their status. Documentation will vary but may include a certified copy of the will or a court order designating the executor(s). A statement by the executor(s) attesting to their status is insufficient. Expatriate. A decedent is an expatriate if the decedent relinquished U.S. citizenship or terminated long-term residency. Special estate tax rules may apply to decedents who expatriated from the United States prior to death. See Taxation Applicable to Certain Expatriates , next. Taxation Applicable to Certain Expatriates Expatriation on or after June 17, 2008. Decedent’s who expatriated on or after June 17, 2008, generally are subject to U.S. estate tax in the same manner as all other NRNC decedents. Note. For decedents who expatriated on or after June 17, 2008, and were “covered expatriates” as defined in section 877A(g)(1), any bequests or other transfers from the covered expatriate decedent’s estate to a U.S. citizen or resident beneficiary may subject the U.S. citizen or resident beneficiary to the section 2801 tax on the receipt of the gift or bequest. For more information on the section 2801 tax, see section 2801. To avoid the potential for subjecting property to both estate tax (payable by the executor of the covered expatriate decedent's estate) and section 2801 tax (payable by the U.S. citizen or resident receiving the property), any required Form 706-NA should be timely filed. See section 2801(e)(2)(B) and Regulations section 28.2801-3(c)(2) for details. Expatriation after June 3, 2004, and before June 17, 2008. Special estate tax rules under section 2107 apply to determine the value of the decedent’s U.S. taxable estate if the decedent was subject to the 10-year alternative tax regime of section 877(b) on the date of death. See the instructions for Line 6a and Line 6b , later. A decedent is subject to the 10-year alternative tax regime of section 877(b) (and thus is subject to section 2107), if the decedent expatriated after June 3, 2004, and before June 17, 2008, and also met one of three tests set out under section 877(a). The decedent’s average annual net income tax liability for the 5 tax years ending before the date of expatriation is: $124,000 for decedents who expatriated in 2004, $127,000 for decedents who expatriated in 2005, $131,000 for decedents who expatriated in 2006, $136,000 for decedents who expatriated in 2007, and $139,000 for decedents who expatriated in 2008. The decedent’s net worth was $2 million or more on the date of expatriation. The decedent’s failure to certify on Form 8854 that the decedent complied with all federal tax obligations for the 5 tax years preceding the date of expatriation. The 10-year alternative tax regime of section 877(b) commences when Form 8854 is filed. See section 877, 2107, and 7701(n) as in effect before June 17, 2008, and Form 8854 for additional information regarding the 10-year alternative tax regime. C6 tax context us_instr_na https://www.irs.gov/instructions/i706na Locator: Form706-NA definitions and special expatriation rules, including distinction from income-tax residence Source date: — Checked: 2026-10-18 [6] Table A—Unified Rate Schedule Column A Taxable amount over Column B Taxable amount not over Column C Tax on amount in column A Column D Rate of tax on excess over amount in column A $0 $10,000 $0 18% 10,000 20,000 1,800 20% 20,000 40,000 3,800 22% 40,000 60,000 8,200 24% 60,000 80,000 13,000 26% 80,000 100,000 18,200 28% 100,000 150,000 23,800 30% 150,000 250,000 38,800 32% 250,000 500,000 70,800 34% 500,000 750,000 155,800 37% 750,000 1,000,000 248,300 39% 1,000,000 – – – – 345,800 40% Line 1 If you elected alternate valuation on Part III, line 1, enter the amount you entered in the “Alternate value” column of Part V, item 13. Otherwise, enter the amount from the “Value at date of death” column. Line 3b. State Death Tax Deduction You may take a deduction on line 3b for estate, inheritance, legacy, or succession taxes paid on any property included in the gross estate as the result of the decedent’s death to any state or the District of Columbia. C6 tax context us_instr_706 https://www.irs.gov/instructions/i706 Locator: addressed_visible_projection:1,000,000 – – – – 345,800 40% Source date: — Checked: 2026-10-18 Current law: unknown. Personal applicability and the particular-case outcome have not been established.

Documents

Documents and recognition

  • ae: What are the recorded scope, issuance and presentation conditions of the European Certificate of Succession for this country and document type? — Recorded rules are available; their applicability to this case has not been established. Regulation No 650/2012 itself establishes neither local ECS issuance nor mandatory acceptance in the United Arab Emirates; the local documentary route requires separate review. The Regulation applies to successions of persons dying on or after 17 August 2015 (Article 83(1)); the death date in this case is unestablished. The Certificate is for heirs, legatees having direct rights, executors and estate administrators who need to invoke status, rights or powers in another participating State. It is issued in a participating State whose courts have jurisdiction under Articles 4, 7, 10 or 11, by a court or another nationally competent authority; the application and evidence are examined under Articles 65–66. The authority shall not issue it, in particular, where certified elements are challenged or it would conflict with a decision covering the same elements. Use is optional and it does not replace domestic documents; once issued for another participating State, it also has effects in the issuing State. In participating States Article 69 effects arise without special procedure: the certified elements and the stated status, rights or powers are presumed accurate. Its suitability for registration does not remove the Article 1(2)(k)–(l) exclusions for rights in rem and registers; Articles 71–73 govern correction, modification, withdrawal, challenges and suspension of effects. The original remains with the issuing authority; a certified copy is normally valid for six months with an expiry date stated on it. In an exceptional, duly justified case its initial validity may be longer; after expiry, an extension of the copy’s validity or a new certified copy is needed for use of the Certificate. This is not a general expiration period for the Certificate itself. Within the Regulation’s route Article 74 waives legalisation and similar formalities for documents issued in a participating State in its context; it does not remove all documentary requirements or itself bind a nonparticipating country to accept such documents without legalisation. — Issuing and receiving authorities, document type, proceeding, entitlement, copy status, translation, asset registration and local requirements remain unestablished; a country flag cannot resolve them. — «Article 1 Scope 1.   This Regulation shall apply to succession to the estates of deceased persons. It shall not apply to revenue, customs or administrative matters. 2.   The following shall be excluded from the scope of this Regulation: (a)  the status of natural persons, as well as family relationships and relationships deemed by the law applicable to such relationships to have comparable effects; (b)  the legal capacity of natural persons, without prejudice to point (c) of Article 23(2) and to Article 26; (c)  questions relating to the disappearance, absence or presumed death of a natural person; (d)  questions relating to matrimonial property regimes and property regimes of relationships deemed by the law applicable to such relationships to have comparable effects to marriage; (e)  maintenance obligations other than those arising by reason of death; (f)  the formal validity of dispositions of property upon death made orally; (g)  property rights, interests and assets created or transferred otherwise than by succession, for instance by way of gifts, joint ownership with a right of survivorship, pension plans, insurance contracts and arrangements of a similar nature, without prejudice to point (i) of Article 23(2); (h)  questions governed by the law of companies and other bodies, corporate or unincorporated, such as clauses in the memoranda of association and articles of association of companies and other bodies, corporate or unincorporated, which determine what will happen to the shares upon the death of the members; (i)  the dissolution, extinction and merger of companies and other bodies, corporate or unincorporated; (j)  the creation, administration and dissolution of trusts; (k)  the nature of rights in rem; and (l)  any recording in a register of rights in immovable or movable property, including the legal requirements for such recording, and the effects of recording or failing to record such rights in a register.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 1; current-official-snapshot-utf8:1487:3717 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 62 Creation of a European Certificate of Succession 1.   This Regulation creates a European Certificate of Succession (hereinafter referred to as ‘the Certificate’) which shall be issued for use in another Member State and shall produce the effects listed in Article 69. 2.   The use of the Certificate shall not be mandatory. 3.   The Certificate shall not take the place of internal documents used for similar purposes in the Member States. However, once issued for use in another Member State, the Certificate shall also produce the effects listed in Article 69 in the Member State whose authorities issued it in accordance with this Chapter.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 62; current-official-snapshot-utf8:51009:51705 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 63 Purpose of the Certificate 1.   The Certificate is for use by heirs, legatees having direct rights in the succession and executors of wills or administrators of the estate who, in another Member State, need to invoke their status or to exercise respectively their rights as heirs or legatees and/or their powers as executors of wills or administrators of the estate. 2.   The Certificate may be used, in particular, to demonstrate one or more of the following: (a)  the status and/or the rights of each heir or, as the case may be, each legatee mentioned in the Certificate and their respective shares of the estate; (b)  the attribution of a specific asset or specific assets forming part of the estate to the heir(s) or, as the case may be, the legatee(s) mentioned in the Certificate; (c)  the powers of the person mentioned in the Certificate to execute the will or administer the estate.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 63; current-official-snapshot-utf8:51718:52708 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 64 Competence to issue the Certificate The Certificate shall be issued in the Member State whose courts have jurisdiction under Article 4, Article 7, Article 10 or Article 11. The issuing authority shall be: (a)  a court as defined in Article 3(2); or (b)  another authority which, under national law, has competence to deal with matters of succession.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 64; current-official-snapshot-utf8:52730:53138 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 65 Application for a Certificate 1.   The Certificate shall be issued upon application by any person referred to in Article 63(1) (hereinafter referred to as ‘the applicant’). 2.   For the purposes of submitting an application, the applicant may use the form established in accordance with the advisory procedure referred to in Article 81(2). 3.   The application shall contain the information listed below, to the extent that such information is within the applicant’s knowledge and is necessary in order to enable the issuing authority to certify the elements which the applicant wants certified, and shall be accompanied by all relevant documents either in the original or by way of copies which satisfy the conditions necessary to establish their authenticity, without prejudice to Article 66(2): (a)  details concerning the deceased: surname (if applicable, surname at birth), given name(s), sex, date and place of birth, civil status, nationality, identification number (if applicable), address at the time of death, date and place of death; (b)  details concerning the applicant: surname (if applicable, surname at birth), given name(s), sex, date and place of birth, civil status, nationality, identification number (if applicable), address and relationship to the deceased, if any; (c)  details concerning the representative of the applicant, if any: surname (if applicable, surname at birth), given name(s), address and representative capacity; (d)  details of the spouse or partner of the deceased and, if applicable, ex-spouse(s) or ex-partner(s): surname (if applicable, surname at birth), given name(s), sex, date and place of birth, civil status, nationality, identification number (if applicable) and address; (e)  details of other possible beneficiaries under a disposition of property upon death and/or by operation of law: surname and given name(s) or organisation name, identification number (if applicable) and address; (f)  the intended purpose of the Certificate in accordance with Article 63; (g)  the contact details of the court or other competent authority which is dealing with or has dealt with the succession as such, if applicable; (h)  the elements on which the applicant founds, as appropriate, his claimed right to succession property as a beneficiary and/or his right to execute the will of the deceased and/or to administer the estate of the deceased; (i)  an indication of whether the deceased had made a disposition of property upon death; if neither the original nor a copy is appended, an indication regarding the location of the original; (j)  an indication of whether the deceased had entered into a marriage contract or into a contract regarding a relationship which may have comparable effects to marriage; if neither the original nor a copy of the contract is appended, an indication regarding the location of the original; (k)  an indication of whether any of the beneficiaries has made a declaration concerning acceptance or waiver of the succession; (l)  a declaration stating that, to the applicant’s best knowledge, no dispute is pending relating to the elements to be certified; (m)  any other information which the applicant deems useful for the purposes of the issue of the Certificate.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 65; current-official-snapshot-utf8:53154:56717 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 66 Examination of the application 1.   Upon receipt of the application the issuing authority shall verify the information and declarations and the documents and other evidence provided by the applicant. It shall carry out the enquiries necessary for that verification of its own motion where this is provided for or authorised by its own law, or shall invite the applicant to provide any further evidence which it deems necessary. 2.   Where the applicant has been unable to produce copies of the relevant documents which satisfy the conditions necessary to establish their authenticity, the issuing authority may decide to accept other forms of evidence. 3.   Where this is provided for by its own law and subject to the conditions laid down therein, the issuing authority may require that declarations be made on oath or by a statutory declaration in lieu of an oath. 4.   The issuing authority shall take all necessary steps to inform the beneficiaries of the application for a Certificate. It shall, if necessary for the establishment of the elements to be certified, hear any person involved and any executor or administrator and make public announcements aimed at giving other possible beneficiaries the opportunity to invoke their rights. 5.   For the purposes of this Article, the competent authority of a Member State shall, upon request, provide the issuing authority of another Member State with information held, in particular, in the land registers, the civil status registers and registers recording documents and facts of relevance for the succession or for the matrimonial property regime or an equivalent property regime of the deceased, where that competent authority would be authorised, under national law, to provide another national authority with such information.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 66; current-official-snapshot-utf8:56739:58595 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 67 Issue of the Certificate 1.   The issuing authority shall issue the Certificate without delay in accordance with the procedure laid down in this Chapter when the elements to be certified have been established under the law applicable to the succession or under any other law applicable to specific elements. It shall use the form established in accordance with the advisory procedure referred to in Article 81(2). The issuing authority shall not issue the Certificate in particular if: (a)  the elements to be certified are being challenged; or (b)  the Certificate would not be in conformity with a decision covering the same elements. 2.   The issuing authority shall take all necessary steps to inform the beneficiaries of the issue of the Certificate.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 67; current-official-snapshot-utf8:58608:59447 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 69 Effects of the Certificate 1.   The Certificate shall produce its effects in all Member States, without any special procedure being required. 2.   The Certificate shall be presumed to accurately demonstrate elements which have been established under the law applicable to the succession or under any other law applicable to specific elements. The person mentioned in the Certificate as the heir, legatee, executor of the will or administrator of the estate shall be presumed to have the status mentioned in the Certificate and/or to hold the rights or the powers stated in the Certificate, with no conditions and/or restrictions being attached to those rights or powers other than those stated in the Certificate. 3.   Any person who, acting on the basis of the information certified in a Certificate, makes payments or passes on property to a person mentioned in the Certificate as authorised to accept payment or property shall be considered to have transacted with a person with authority to accept payment or property, unless he knows that the contents of the Certificate are not accurate or is unaware of such inaccuracy due to gross negligence. 4.   Where a person mentioned in the Certificate as authorised to dispose of succession property disposes of such property in favour of another person, that other person shall, if acting on the basis of the information certified in the Certificate, be considered to have transacted with a person with authority to dispose of the property concerned, unless he knows that the contents of the Certificate are not accurate or is unaware of such inaccuracy due to gross negligence. 5.   The Certificate shall constitute a valid document for the recording of succession property in the relevant register of a Member State, without prejudice to points (k) and (l) of Article 1(2).» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 69; current-official-snapshot-utf8:62203:64099 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 70 Certified copies of the Certificate 1.   The issuing authority shall keep the original of the Certificate and shall issue one or more certified copies to the applicant and to any person demonstrating a legitimate interest. 2.   The issuing authority shall, for the purposes of Articles 71(3) and 73(2), keep a list of persons to whom certified copies have been issued pursuant to paragraph 1. 3.   The certified copies issued shall be valid for a limited period of six months, to be indicated in the certified copy by way of an expiry date. In exceptional, duly justified cases, the issuing authority may, by way of derogation, decide that the period of validity is to be longer. Once this period has elapsed, any person in possession of a certified copy must, in order to be able to use the Certificate for the purposes indicated in Article 63, apply for an extension of the period of validity of the certified copy or request a new certified copy from the issuing authority.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 70; current-official-snapshot-utf8:64112:65138 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 71 Rectification, modification or withdrawal of the Certificate 1.   The issuing authority shall, at the request of any person demonstrating a legitimate interest or of its own motion, rectify the Certificate in the event of a clerical error. 2.   The issuing authority shall, at the request of any person demonstrating a legitimate interest or, where this is possible under national law, of its own motion, modify or withdraw the Certificate where it has been established that the Certificate or individual elements thereof are not accurate. 3.   The issuing authority shall without delay inform all persons to whom certified copies of the Certificate have been issued pursuant to Article 70(1) of any rectification, modification or withdrawal thereof.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 71; current-official-snapshot-utf8:65151:65951 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 72 Redress procedures 1.   Decisions taken by the issuing authority pursuant to Article 67 may be challenged by any person entitled to apply for a Certificate. Decisions taken by the issuing authority pursuant to Article 71 and point (a) of Article 73(1) may be challenged by any person demonstrating a legitimate interest. The challenge shall be lodged before a judicial authority in the Member State of the issuing authority in accordance with the law of that State. 2.   If, as a result of a challenge as referred to in paragraph 1, it is established that the Certificate issued is not accurate, the competent judicial authority shall rectify, modify or withdraw the Certificate or ensure that it is rectified, modified or withdrawn by the issuing authority. If, as a result of a challenge as referred to in paragraph 1, it is established that the refusal to issue the Certificate was unjustified, the competent judicial authority shall issue the Certificate or ensure that the issuing authority re-assesses the case and makes a fresh decision.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 72; current-official-snapshot-utf8:65964:67059 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 73 Suspension of the effects of the Certificate 1.   The effects of the Certificate may be suspended by: (a)  the issuing authority, at the request of any person demonstrating a legitimate interest, pending a modification or withdrawal of the Certificate pursuant to Article 71; or (b)  the judicial authority, at the request of any person entitled to challenge a decision taken by the issuing authority pursuant to Article 72, pending such a challenge. 2.   The issuing authority or, as the case may be, the judicial authority shall without delay inform all persons to whom certified copies of the Certificate have been issued pursuant to Article 70(1) of any suspension of the effects of the Certificate. During the suspension of the effects of the Certificate no further certified copies of the Certificate may be issued. CHAPTER VII GENERAL AND FINAL PROVISIONS» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 73; current-official-snapshot-utf8:67069:68040 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 74 Legalisation and other similar formalities No legalisation or other similar formality shall be required in respect of documents issued in a Member State in the context of this Regulation.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 74; current-official-snapshot-utf8:68047:68257 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Article 83 Transitional provisions 1.   This Regulation shall apply to the succession of persons who die on or after 17 August 2015. 2.   Where the deceased had chosen the law applicable to his succession prior to 17 August 2015, that choice shall be valid if it meets the conditions laid down in Chapter III or if it is valid in application of the rules of private international law which were in force, at the time the choice was made, in the State in which the deceased had his habitual residence or in any of the States whose nationality he possessed. 3.   A disposition of property upon death made prior to 17 August 2015 shall be admissible and valid in substantive terms and as regards form if it meets the conditions laid down in Chapter III or if it is admissible and valid in substantive terms and as regards form in application of the rules of private international law which were in force, at the time the disposition was made, in the State in which the deceased had his habitual residence or in any of the States whose nationality he possessed or in the Member State of the authority dealing with the succession. 4.   If a disposition of property upon death was made prior to 17 August 2015 in accordance with the law which the deceased could have chosen in accordance with this Regulation, that law shall be deemed to have been chosen as the law applicable to the succession.» — Regulation (EU) 650/2012 — current consolidated English text — https://op.europa.eu/o/opportal-service/download-handler?identifier=06e4940f-eb4f-4e63-8e29-c3b9c0bd45af&format=xhtml&language=en&productionSystem=cellar&part= — Article 83; current-official-snapshot-utf8:74702:76141 — Source date: 2012-07-04 — Verified: 2026-10-17 — «Pages (27) RSS Showing results 1 to 20 Austria EU Member State since 1995, Euro area member since 1999, Schengen area member since 1997 and more about Austria’s participation in the EU. Belgium EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Belgium’s participation in the EU. Bulgaria EU Member State since 2007, Euro area member since 2026, Schengen area member since 2024 and more about Bulgaria's participation in the EU. Croatia EU Member State since 2013, Euro area member since 2023, Schengen area member since 2023 and more about Croatia’s participation in the EU. Cyprus EU Member State since 2004, Euro area member since 2008, and more about Cyprus’s participation in the EU. Czechia EU Member State since 2004, Schengen area member since 2007 and more about Czechia’s participation in the EU. Denmark EU Member State since 1973, Schengen area member since 2001 and more about Denmark’s participation in the EU. Estonia EU Member State since 2004, Euro area member since 2011, Schengen area member since 2007 and more about Estonia’s participation in the EU. Finland EU Member State since 1995, Euro area member since 1999, Schengen area member since 2001 and more about Finland’s participation in the EU. France EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about France’s participation in the EU. Germany EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Germany’s participation in the EU. Greece EU Member State since 1981, Euro area member since 2001, Schengen area member since 2000 and more about Greece’s participation in the EU. Hungary EU Member State since 2004, Schengen area member since 2007 and more about Hungary’s participation in the EU. Ireland EU Member State since 1973, Euro area member since 1999 and more about Ireland’s participation in the EU. Italy EU Member State since 1958, Euro area member since 1999, Schengen area member since 1997 and more about Italy’s participation in the EU. Latvia EU Member State since 2004, Euro area member since 2014, Schengen area member since 2007 and more about Latvia’s participation in the EU. Lithuania EU Member State since 2004, Euro area member since 2015, Schengen area member since 2007 and more about Lithuania’s participation in the EU. Luxembourg EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Luxembourg’s participation in the EU. Malta EU Member State since 2004, Euro area member since 2008, Schengen area member since 2007 and more about Malta’s participation in the EU. Netherlands EU Member State since 1958, Euro area member since 1999, Schengen area member since 1995 and more about Dutch participation in the EU. 1 Page 1 2 Next » — EU countries — official list page 1 of 2 — https://european-union.europa.eu/principles-countries-history/eu-countries_en — members_complete_page1; current-official-snapshot-utf8:1980:4855 — Verified: 2026-10-17 — «Pages (27) RSS Showing results 20 to 27 Poland EU Member State since 2004, Schengen area member since 2007 and more about Poland’s participation in the EU. Portugal EU Member State since 1986, Euro area member since 1999, Schengen area member since 1995 and more about Portugal’s participation in the EU. Romania EU Member State since 2007, Schengen area member since 2024 and more about Romania’s participation in the EU. Slovakia EU Member State since 2004, Euro area member since 2009, Schengen area member since 2007 and more about Slovakia’s participation in the EU. Slovenia EU Member State since 2004, Euro area and Schengen area member since 2007 and more about Slovenia’s participation in the EU. Spain EU Member State since 1986, Euro area member since 1999, Schengen area member since 1995 and more about Spain’s participation in the EU. Sweden EU Member State since 1995, Schengen area member since 2001 and more about Sweden’s participation in the EU. Previous 1 2 Page 2 » — EU countries — official list page 2 of 2 — https://european-union.europa.eu/principles-countries-history/eu-countries_en?page=1 — members_complete_page2; current-official-snapshot-utf8:1980:2979 — Verified: 2026-10-17 — «The Regulation applies between all Member States except Denmark and Ireland. The Regulation also introduces a European Certificate of Succession (ECS).» — European e-Justice: European Certificate of Succession — https://online-forms.e-justice.europa.eu/online-forms/european-certificate-succession_en — ecs_1; current-official-snapshot-utf8:971:1122 — Verified: 2026-10-17 — Recorded regulation context only; personal applicability and governing law: unknown.
  • ae / succ.foreign.grant: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.foreign.hague1985: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.foreign.lookthrough: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.proc.authority: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.proc.acceptance: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.proc.certificate: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • ae / succ.proc.taxreturn: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.foreign.grant: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.foreign.hague1985: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.foreign.lookthrough: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.proc.authority: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.proc.acceptance: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.proc.certificate: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]
  • us / succ.proc.taxreturn: no exact reviewed whole context is mapped to this fragment. A separate record, conditions and primary source are required; the particular-case conclusion is not established. [current_native_not_admitted]

United Arab Emirates: reviewed answers with sources

Is the country a party to the 1961 Hague Convention on the form of testamentary dispositions

Recorded rules are available; their applicability to this case has not been established.

not a party

  • HCCH Convention status table and declarations — Contracting Parties and Signatories to this Convention that are also Members of the HCCH (i.e., the Organisation) are in bold ; Contracting Parties and Signatories that are not Members of the HCCH are in italics . — 1961 Convention — complete contracting-party roster (country absence checked against entire table) — Checked: 2026-10-07

United States: reviewed answers with sources

Which limits on testamentary freedom arise from the surviving-spouse election under New York EPTL5-1.1-A?

Recorded rules are available; their applicability to this case has not been established.

The retained full EPTL5-1.1-A gives a qualifying surviving spouse a personal election, subject to death-date conditions and net-estate, testamentary-substitute and credit rules. The greater-of50000dollars(or the smaller netestate) and one-third formula is not a general heir allowance or unconditional payment. The full section contains limits, procedural election, deadlines and waiver; applicability, death, domicile, assets and renunciation need separate review. This example defeats an unrestricted-testamentary-freedom claim for allU.S. states, but establishes no other state’s law.

where (part of the country): New York (state)

This records the named sources; it does not determine personal entitlement, the exhaustive currently governing rule or applicability to a particular case. Territory, dates, documents, party facts and exceptions require separate assessment. England and Wales under the1975Act and separately NewYork under EPTL; not allUK/USA or an automatic share for every relative.

  • New York EPTL 5-1.1-A — §5-1.1-A complete addressed web-tool lines52-371 — § 5-1.1-A Right of election by surviving spouse (a) Where a decedent dies on or after September first, nineteen hundred ninety-two and is survived by a spouse, a personal right of election is given to the surviving spouse to take a share of the decedent's estate, subject to the following: (1) For the purpose of this section, the decedent's estate includes the capital value, as of the decedent's death, of any property described in subparagraph (b) (1). (2) The elective share, as used in this paragraph, is the pecuniary amount equal to the greater of (i) fifty thousand dollars or, if the capital value of the net estate is less than fifty thousand dollars, such capital value, or (ii) one third of the net estate. In computing the net estate, debts, administration expenses and reasonable funeral expenses shall be deducted, but all estate taxes shall be disregarded, except that nothing contained herein relieves the surviving spouse from contributing to all such taxes the amounts apportioned against him or her under 2-1.8. (3) The term "testamentary provision", as used in this paragraph, includes, in addition to dispositions made by the decedent's will, distributions of property pursuant to 4-1.1 and any transaction described as a testamentary substitute in subparagraph (b) (1). (4) The share of the testamentary provisions to which the surviving spouse is entitled hereunder (the "net elective share") is his or her elective share, as defined in subparagraphs (1) and (2), reduced by the capital value of any interest which passes absolutely from the decedent to such spouse, or which would have passed absolutely from the decedent to such spouse but was renounced by the spouse, (i) by intestacy, (ii) by testamentary substitute as described in subparagraph (b) (1), or (iii) by disposition under the decedent's last will. (A) Unless the decedent has provided otherwise, if a spouse elects under this section, such election shall have the same effect with respect to any interest which passes or would have passed to the spouse, other than absolutely, as though the spouse died on the same date but immediately before the death of the decedent. (B) For the purposes of this subparagraph (4), (i) an interest in property shall be deemed to pass other than absolutely from the decedent to the spouse if the interest so passing consists of less than the decedent's entire interest in that property or consists of any interest in a trust or trust equivalent created by the decedent; and (ii) an interest in property shall be deemed to pass absolutely from the decedent to the spouse if it is not deemed to pass other than absolutely. (5) Where a decedent dies before September first, nineteen hundred ninety-four, paragraphs (c)(1)(D) through (c)(1)(K) of section 5-1.1 shall apply except that the words "fifty thousand dollars" shall be substituted for the words "ten thousand dollars" wherever they appear in such paragraphs. (b) Inter vivos dispositions treated as testamentary substitutes for the purpose of election by surviving spouse. (1) Where a person dies after August thirty-first, nineteen hundred ninety-two and is survived by a spouse who exercises a right of election under paragraph (a), the transactions affected by and property interests of the decedent described in clauses (A) through (H), whether benefiting the surviving spouse or any other person, shall be treated as testamentary substitutes and the capital value thereof, as of the decedent's death, shall be included in the net estate subject to the surviving spouse's elective right except to the extent that the surviving spouse has executed a waiver of release pursuant to paragraph (e) with respect thereto. Notwithstanding the foregoing, a transaction, other than a transaction described in clause (G), that is irrevocable or is revocable only with the consent of a person having a substantial adverse interest (including any such transactions with respect to which the decedent retained a special power of appointment as defined in 10-3.2), will constitute a testamentary substitute only if it is effected after the date of the marriage. (A) Gifts causa mortis. (B) The aggregate transfers of property (including the transfer, release or relinquishment of any property interest which, but for such transfer, release or relinquishment, would come within the scope of clause (F)), other than gifts causa mortis and transfers coming within the scope of clauses (G) and (H), to or for the benefit of any person, made after August thirty-first, nineteen hundred ninety-two, and within one year of the death of the decedent, to the extent that the decedent did not receive adequate and full consideration in money or money's worth for such transfers; provided, however, that any portion of any such transfer that was excludible from taxable gifts pursuant to subsections (b) and (e) of section two thousand five hundred three of the United States Internal Revenue Code, including any amounts excluded as a result of the election by the surviving spouse to treat any such transfer as having been made one half by him or her, shall not be treated as a testamentary substitute. (C) Money deposited, together with all dividends or interest credited thereon, in a savings account in the name of the decedent in trust for another person, with a banking organization, savings and loan association, foreign banking corporation or organization or bank or savings and loan association organized under the laws of the United States, and remaining on deposit at the date of the decedent's death. (D) Money deposited after August thirty-first, nineteen hundred sixty-six, together with all dividends or interest credited thereon, in the name of the decedent and another person and payable on death, pursuant to the terms of the deposit or by operation of law, to the survivor, with a banking organization, savings and loan association, foreign banking corporation or organization or bank or savings and loan association organized under the laws of the United States, and remaining on deposit at the date of the decedent's death. (E) Any disposition of property made by the decedent whereby property, at the date of his or her death, is held (i) by the decedent and another person as joint tenants with a right of survivorship or as tenants by the entirety where the disposition was made after August thirty-first, nineteen hundred sixty-six, or (ii) by the decedent and is payable on his or her death to a person other than the decedent or his or her estate. (F) Any disposition of property or contractual arrangement made by the decedent, in trust or otherwise, to the extent that the decedent (i) after August thirty-first, nineteen hundred ninety-two, retained for his or her life or for any period not ascertainable without reference to his or her death or for any period which does not in fact end before his or her death the possession or enjoyment of, or the right to income from, the property except to the extent that such disposition or contractual arrangement was for an adequate consideration in money or money's worth; or (ii) at the date of his or her death retained either alone or in conjunction with any other person who does not have a substantial adverse interest, by the express provisions of the disposing instrument, a power to revoke such disposition or a power to consume, invade or dispose of the principal thereof. The provisions of this subparagraph shall not affect the right of any income beneficiary to the income undistributed or accrued at the date of death nor shall they impair or defeat any right which has vested on or before August thirty-first, nineteen hundred ninety-two. (G) Any money, securities or other property payable under a thrift, savings, retirement, pension, deferred compensation, death benefit, stock bonus or profit-sharing plan, account, arrangement, system or trust, except that with respect to a plan to which subsection (a) (11) of section four hundred one of the United States Internal Revenue Code applies or a defined contribution plan to which such subsection does not apply pursuant to paragraph (B) (iii) thereof, only to the extent of fifty percent of the capital value thereof. Notwithstanding the foregoing, a transaction described herein shall not constitute a testamentary substitute if the decedent designated the beneficiary or beneficiaries of the plan benefits on or before September first, nineteen hundred ninety-two and did not change such beneficiary designation thereafter. (H) Any interest in property to the extent the passing of the principal thereof to or for the benefit of any person was subject to a presently exercisable general power of appointment, as defined in section two thousand forty-one of the United States Internal Revenue Code, held by the decedent immediately before his or her death or which the decedent, within one year of his or her death, released (except to the extent such release results from a lapse of the power which is not treated as a release pursuant to section two thousand forty-one of the United States Internal Revenue Code) or exercised in favor of any person other than himself or herself or his or her estate. (I) A transfer of a security to a beneficiary pursuant to part 4 of article 13 of this chapter. (2) Transactions described in clause (D) or (E) (i) shall be treated as testamentary substitutes in the proportion that the funds on deposit were the property of the decedent immediately before the deposit or the consideration for the property described in clause (E) (i) was furnished by the decedent. The surviving spouse shall have the burden of establishing the proportion of the decedent's contribution; provided, however, that where the surviving spouse is the other party to the transaction, it will be conclusively presumed that the proportion of the decedent's contribution is one-half. For the purpose of this subparagraph, the court may accept such evidence as is relevant and competent, whether or not the person offering such evidence would otherwise be competent to testify. (3) The property referred to in clause (E) shall include United States savings bonds and other United States obligations. (4) The provisions of this paragraph shall not prevent a corporation or other person from paying or transferring any funds or property to a person otherwise entitled thereto, unless there has been served personally upon such corporation or other person a certified copy of an order enjoining such payment or transfer made by the surrogate's court having jurisdiction of the decedent's estate or by another court of competent jurisdiction. A corporation or other person paying or transferring any funds or property described in clause (G) of subparagraph one of this paragraph to a person otherwise entitled thereto, shall be held harmless and free from any liability for making such payment or transfer, in any action or proceeding which involves such funds or property. Such order may be made, on notice to such persons and in such manner as the court may direct, upon application of the surviving spouse or any other interested party and on proof that the surviving spouse has exercised his or her right of election under paragraph (a). Service of a certified copy of such order on the corporation or other person holding such fund or property shall be a defense, during the effective period of the order, in any action or proceeding which involves such fund or property. (5) This paragraph shall not impair or defeat the rights of creditors of the decedent with respect to any matter as to which any such creditor has rights. (6) In case of a conflict between this paragraph and any other provision of law affecting the transactions described in subparagraph (1) of this paragraph, this paragraph controls. (7) If any part of this section is preempted by federal law with respect to a payment or an item of property included in the net estate, a person who, not for value, received that payment or item of property is obligated to return to the surviving spouse that payment or item of property or is personally liable to the surviving spouse for the amount of that payment or the value of that item of property, to the extent required under this section. (c) General provisions governing right of election. (1) Where an election has been made under this section, the will or other instrument making a testamentary provision, as the case may be, is valid as to the residue after the share to which the surviving spouse is entitled has been deducted, and the terms of such will or instrument remain otherwise effective so far as possible, subject, however, to the provisions of clause (a)(4)(A). (2) Except as otherwise expressly provided in the will or other instrument making a testamentary provision, ratable contribution to the share to which the surviving spouse is entitled shall be made by the beneficiaries and distributees (including the recipients of any such testamentary provision), other than the surviving spouse, under the decedent's will, by intestacy and other instruments making testamentary provisions, which contribution may be made in cash or in the specific property received from the decedent by the person required to make such contribution or partly in cash and partly in such property as such person in his or her discretion shall determine. (3) The right of election is personal to the surviving spouse, except that an election may be made by: (A) The guardian of the property of an infant spouse, when so authorized by the court having jurisdiction of the decedent's estate. (B) The committee of an incompetent spouse, when so authorized by the court that appointed the committee. (C) The conservator of a conservatee spouse, when so authorized by the court that appointed the conservator. (D) The guardian ad litem for the surviving spouse when so authorized by the court that appointed such guardian. (E) A guardian authorized under Article 81 of the mental hygiene law, when so authorized by the court that appointed the guardian. (4) Any question arising as to the right of election shall be determined by the court having jurisdiction of the decedent's estate in a proceeding brought for that purpose on notice to all interested persons in such manner as the court may direct, or in a proceeding for the judicial settlement of the accounts of the personal representative. (5) Upon application by a surviving spouse who has made an election under this section, the court may make an order cancelling such election, provided that no adverse rights have intervened and no prejudice is shown to creditors of such spouse or other persons interested in the estate. Such application shall be made on notice to such persons and in such manner as the court may direct. A certified copy of such order shall be indexed and recorded in the same manner as a notice of pendency of an action in the office of the clerk of the county in which any real property of the decedent is situated. (6) The right of election granted by this section is not available to the spouse of a decedent who was not domiciled in this state at the time of death, unless such decedent has elected, under paragraph (h) of 3-5.1, to have the disposition of his or her property situated in this state governed by the laws of this state. (7) The decedent's estate shall include all property of the decedent wherever situated. (8) An election made by the surviving spouse under this section is in lieu of any right of dower to which such spouse may be entitled. (9) The references in this paragraph to sections of the United States Internal Revenue Code are to the Internal Revenue Code of 1986, as amended. Such references, however, shall be deemed to constitute references to any corresponding provisions of any subsequent federal tax code. (d) Procedure for exercise of right of election. (1) An election under this section must be made within six months from the date of issuance of letters testamentary or of administration, as the case may be, but in no event later than two years after the date of decedent's death, except as otherwise provided in subparagraph 2 of this paragraph. Written notice of such election shall be served upon any personal representative in the manner herein provided, or upon a person named as executor in a will on file in the surrogate's court in a case where such will has not yet been admitted to probate, and the original thereof shall be filed and recorded, with proof of service, in the surrogate's court in which such letters were issued within six months from the date of the issuance of letters but in no event later than two years from the date of decedent's death, except as otherwise provided in subparagraph 2 of this paragraph. Such notice may be served by mailing a copy thereof, addressed to any personal representative, or to the nominated executor, as the case may be, at the place of residence stated in the designation required by section 708 of the surrogate's court procedure act, to the domicile address of such nominated executor, or in such other manner as the surrogate may direct. (2) The time to make such election may be extended before expiration by an order of the surrogate's court from which such letters issued for a further period not exceeding six months upon any one application. If the spouse defaults in filing such election within the time provided in subparagraph (1) of this paragraph, the surrogate's court may relieve the spouse from such default and authorize the making of an election within the period fixed by the order, provided that no decree settling the account of the personal representative has been made and that twelve months have not elapsed since the issuance of the letters, and two years have not elapsed since the decedent's date of death, in the case of initial application; except that the court may, in its discretion for good cause shown, extend the time to make such election beyond such period of two years. An application for relief from the default and for an extension of time to elect shall be made upon a petition showing reasonable cause and on notice to such persons and in such manner as the surrogate may direct. A certified copy of such order shall be indexed and recorded in the same manner as a notice of pendency of an action in the office of the clerk of each county in which real property of the decedent is situated. (3) The time limited in this paragraph for making an election is exclusive and shall not be suspended or otherwise affected by any provision of law, except that the surrogate may, in his or her discretion, permit an election to be made in behalf of an infant or incompetent spouse at any time up to, but no later than, the entry of the decree of the first judicial account of the representative of the estate, made more than seven months after the issuance of letters. (e) Waiver or release of right of election. (1) A spouse, during the lifetime of the other, may waive or release a right of election, granted by this section, against a particular or any last will or a testamentary substitute, as described in subparagraph (b) (1) made by the other spouse. A waiver or release of all rights in the estate of the other spouse is a waiver or release of a right of election against any such last will or testamentary provision. (2) To be effective under this section, a waiver or release must be in writing and subscribed by the maker thereof, and acknowledged or proved in the manner required by the laws of this state for the recording of a conveyance of real property. (3) Such a waiver or release is effective, in accordance with its terms, whether: (A) Executed before or after the marriage of the spouses. (B) Executed before, on or after September first, nineteen hundred sixty-six. (C) Unilateral in form, executed only by the maker thereof, or bilateral in form, executed by both spouses. (D) Executed with or without consideration. (E) Absolute or conditional. (4) If there is in effect at the time of the decedent's death a waiver, or a consent to the decedent's waiver, executed by the surviving spouse with respect to any survivor benefit, or right to such benefit, under subsection (a) (11) of section four hundred one or section four hundred seventeen of the United States Internal Revenue Code, then such waiver shall be deemed to be a waiver within the meaning of this paragraph (e) against the testamentary substitute constituting such benefit. — §5-1.1-A complete addressed web-tool lines52-371 — Source date: 2018-08-31 — Checked: 2026-10-18
What is the general inheritance tax context in this jurisdiction?

Recorded rules are available; their applicability to this case has not been established.

US federal estate tax uses a progressive schedule with a top 40% marginal rate above $1 million of the relevant tax-computation amount. For a decedent who at death was neither US domiciled nor a US citizen for estate-tax purposes, the executor must file Form 706-NA if death-date US-situs assets, the specified gift-tax exemption for gifts made from 9 September through 31 December 1976, and adjusted taxable gifts after 31 December 1976 together exceed $60,000. The ordinary maximum unified credit of $13,000 corresponds to tax on the first $60,000 under the base schedule; treaties, US-territory and expatriation rules and other conditions can change the calculation. Stock issued by a US-law corporation is generally US situs. These are decedent-estate rules, not a personal allowance for a foreign heir.

This is general source context. Estate assets, death date, decedent and heir status, kinship, reliefs, treaties and local rules require review; no personal tax is calculated here.

  • C6 tax context us_nrnc — To the taxable estate, add the value of lifetime taxable gifts, beginning with gifts made in 1977, of tangible or intangible property located in the United States that was transferred directly or indirectly, and not included in the gross estate. If the date of death value of the decedent’s U.S.-situated assets, together with the gift tax specific exemption and the amount of the adjusted taxable gifts, exceeds the filing threshold of $60,000, the executor must file a Form 706-NA for the decedent’s estate. The filing threshold for Form 706-NA is not indexed for inflation. See the Instructions for Form 706-NA for additional information on the gift tax specific exemption and the amount of adjusted taxable gifts. The Form 706-NA, United States Estate (and Generation-Skipping Transfer) Tax Return Estate of nonresident not a citizen of the United States , if required, must be filed within 9 months after the date of death unless an extension of time to file was granted. — addressed_visible_projection:filing threshold of $60,000 — Checked: 2026-10-18
  • C6 tax context us_situs — For estate tax purposes, a citizen of a U.S. possession is not a U.S. citizen. U.S.-situated assets that are subject to estate tax include, for example: Real estate located in the U.S., Tangible personal property (excluding some art), and Stock of corporations organized in or under U.S. law, even if the nonresident held the certificates abroad or registered the certificates in the name of a nominee. Examples of property treated as situated outside the U.S., and therefore not subject to the U.S. estate tax, include certain deposits and debt obligations described in Section 871(g)-(i), bank accounts deposited with a foreign branch of a domestic commercial banking business, and proceeds of life insurance on the life of a nonresident who is not a U.S. citizen. — IRS US-situs examples and complete concluding excluded-property sentence — Checked: 2026-10-18
  • C6 tax context us_instr_na — Department of the Treasury Internal Revenue Service Center Kansas City, MO 64999 Part II—Tax Computation Lines 4 and 5 To determine the tentative tax on the amount on line 2 (to be entered on line 5) and the tentative tax on the amount on line 3 (to be entered on line 4), use Table A—Unified Rate Schedule in the version of the Instructions for Form 706 that corresponds to the decedent's date of death. Line 7 Enter the unified credit. The unified credit is allowed for the smaller of the line 6 amount or the maximum unified credit. In general, the maximum unified credit is $13,000. For a citizen of a U.S. territory (see section 2209), the maximum unified credit is the greater of: $13,000, or The product of $46,800 times a fraction. The numerator of the fraction is the part of the gross estate located in the United States (line 1 of Part IV), and the denominator is the entire gross estate wherever located (line 3 of Part IV). If the unified credit is affected by a treaty, see section 2102(b)(3)(A). — addressed_visible_projection:maximum unified credit is $13,000 — Checked: 2026-10-18
  • C6 tax context us_instr_na — Who Must File The executor must file Form 706-NA if the date of death value of the decedent’s U.S.-situated assets, together with the gift tax specific exemption and the amount of adjusted taxable gifts, exceeds the filing threshold of $60,000. The gift tax specific exemption refers to the amount allowed for gifts made by the decedent between September 9, 1976, and December 31, 1976, inclusive. The amount of adjusted taxable gifts refers to the amount of adjusted taxable gifts made by the decedent after December 31, 1976. — Form706-NA complete filing formula and historic gift definitions — Checked: 2026-10-18
  • C6 tax context us_instr_na — Definitions The following definitions apply in these instructions. United States. The United States means the 50 states and the District of Columbia. Domicile. For estate tax purposes, a person acquires domicile in a place by living there, for even a brief period of time, with no definite present intention of later moving. See Regulations section 20.0-1 for more information. Nonresident not a citizen of the United States (NRNC). For estate tax purposes, a decedent is a nonresident not a citizen of the United States (NRNC) if the decedent is neither domiciled in nor a citizen of the United States at the time of death. A decedent who acquired U.S. citizenship solely by reason of being a citizen of a U.S. territory or by reason of birth or residence within a U.S. territory is not treated as a U.S. citizen. Note. A decedent may be a U.S. resident for income tax purposes yet be considered a nonresident for estate tax purposes. Long-term U.S. resident. A long-term U.S. resident is an individual (other than a U.S. citizen) who has been a lawful permanent resident of the United States (green card holder) for income tax purposes in at least 8 of the last 15 tax years ending with the tax year in which U.S. income tax residency is terminated. For more information, see section 877(e). For information regarding the definition of lawful permanent resident, including circumstances in which the lawful permanent resident status of a treaty resident is considered terminated, see the Instructions for Form 8854, Initial and Annual Expatriation Statement. Executor. An executor is the personal representative, executor, executrix, administrator, or administratrix of the decedent’s estate. If no executor is appointed, qualified, and acting in the United States, every person in actual or constructive possession of any of the decedent's property is considered an executor and must file a return. If more than one person must file, it is preferable that they join in filing one complete return. Otherwise, each person must file as complete a return as possible, including a full description of the property and each person's name who holds an interest in it. Executors must provide documentation proving their status. Documentation will vary but may include a certified copy of the will or a court order designating the executor(s). A statement by the executor(s) attesting to their status is insufficient. Expatriate. A decedent is an expatriate if the decedent relinquished U.S. citizenship or terminated long-term residency. Special estate tax rules may apply to decedents who expatriated from the United States prior to death. See Taxation Applicable to Certain Expatriates , next. Taxation Applicable to Certain Expatriates Expatriation on or after June 17, 2008. Decedent’s who expatriated on or after June 17, 2008, generally are subject to U.S. estate tax in the same manner as all other NRNC decedents. Note. For decedents who expatriated on or after June 17, 2008, and were “covered expatriates” as defined in section 877A(g)(1), any bequests or other transfers from the covered expatriate decedent’s estate to a U.S. citizen or resident beneficiary may subject the U.S. citizen or resident beneficiary to the section 2801 tax on the receipt of the gift or bequest. For more information on the section 2801 tax, see section 2801. To avoid the potential for subjecting property to both estate tax (payable by the executor of the covered expatriate decedent's estate) and section 2801 tax (payable by the U.S. citizen or resident receiving the property), any required Form 706-NA should be timely filed. See section 2801(e)(2)(B) and Regulations section 28.2801-3(c)(2) for details. Expatriation after June 3, 2004, and before June 17, 2008. Special estate tax rules under section 2107 apply to determine the value of the decedent’s U.S. taxable estate if the decedent was subject to the 10-year alternative tax regime of section 877(b) on the date of death. See the instructions for Line 6a and Line 6b , later. A decedent is subject to the 10-year alternative tax regime of section 877(b) (and thus is subject to section 2107), if the decedent expatriated after June 3, 2004, and before June 17, 2008, and also met one of three tests set out under section 877(a). The decedent’s average annual net income tax liability for the 5 tax years ending before the date of expatriation is: $124,000 for decedents who expatriated in 2004, $127,000 for decedents who expatriated in 2005, $131,000 for decedents who expatriated in 2006, $136,000 for decedents who expatriated in 2007, and $139,000 for decedents who expatriated in 2008. The decedent’s net worth was $2 million or more on the date of expatriation. The decedent’s failure to certify on Form 8854 that the decedent complied with all federal tax obligations for the 5 tax years preceding the date of expatriation. The 10-year alternative tax regime of section 877(b) commences when Form 8854 is filed. See section 877, 2107, and 7701(n) as in effect before June 17, 2008, and Form 8854 for additional information regarding the 10-year alternative tax regime. — Form706-NA definitions and special expatriation rules, including distinction from income-tax residence — Checked: 2026-10-18
  • C6 tax context us_instr_706 — Table A—Unified Rate Schedule Column A Taxable amount over Column B Taxable amount not over Column C Tax on amount in column A Column D Rate of tax on excess over amount in column A $0 $10,000 $0 18% 10,000 20,000 1,800 20% 20,000 40,000 3,800 22% 40,000 60,000 8,200 24% 60,000 80,000 13,000 26% 80,000 100,000 18,200 28% 100,000 150,000 23,800 30% 150,000 250,000 38,800 32% 250,000 500,000 70,800 34% 500,000 750,000 155,800 37% 750,000 1,000,000 248,300 39% 1,000,000 – – – – 345,800 40% Line 1 If you elected alternate valuation on Part III, line 1, enter the amount you entered in the “Alternate value” column of Part V, item 13. Otherwise, enter the amount from the “Value at date of death” column. Line 3b. State Death Tax Deduction You may take a deduction on line 3b for estate, inheritance, legacy, or succession taxes paid on any property included in the gross estate as the result of the decedent’s death to any state or the District of Columbia. — addressed_visible_projection:1,000,000 – – – – 345,800 40% — Checked: 2026-10-18
Does the country levy an inheritance or estate tax

Recorded rules are available; their applicability to this case has not been established.

estate tax

  • Instructions for Form706 (RevJuly2026) — The executor of a decedent’s estate uses Form 706 to figure the estate tax imposed by chapter 11 of the Internal Revenue Code. This tax is levied on the entire taxable estate and not just on the share received by a particular beneficiary. — Purpose of Form — Checked: 2026-10-07
What is charged on succession: the estate, the heir's acquisition, the gratuitous transfer (stamp duty) or a deemed disposal at death

Recorded rules are available; their applicability to this case has not been established.

estate tax

  • Instructions for Form706 (RevJuly2026) — The executor of a decedent’s estate uses Form 706 to figure the estate tax imposed by chapter 11 of the Internal Revenue Code. This tax is levied on the entire taxable estate and not just on the share received by a particular beneficiary. — Purpose of Form — Checked: 2026-10-07
Is the deceased's worldwide estate taxed where the deceased was connected with the country (residence, domicile, citizenship)

Recorded rules are available; their applicability to this case has not been established.

US citizenship or US domicile at death — worldwide

who: citizen (national)

  • Instructions for Form706 (RevJuly2026) — File Form 706 for the estates of decedents who were either U.S. citizens or U.S. residents at the time of death. For estate tax purposes, a resident is someone who had a domicile in the United States at the time of death. — Citizens/residents/domicile — Checked: 2026-10-07
  • Instructions for Form706 (RevJuly2026) — The gross estate includes all property in which the decedent had an interest (including property outside the United States). — Gross Estate — Checked: 2026-10-07

US citizenship or US domicile at death — worldwide

who: domiciled in the country

  • Instructions for Form706 (RevJuly2026) — File Form 706 for the estates of decedents who were either U.S. citizens or U.S. residents at the time of death. For estate tax purposes, a resident is someone who had a domicile in the United States at the time of death. — Citizens/residents/domicile — Checked: 2026-10-07
  • Instructions for Form706 (RevJuly2026) — The gross estate includes all property in which the decedent had an interest (including property outside the United States). — Gross Estate — Checked: 2026-10-07
Is the country a party to the 1961 Hague Convention on the form of testamentary dispositions

Recorded rules are available; their applicability to this case has not been established.

not a party

  • HCCH Convention status table and declarations — Contracting Party S 1 R/A/S 2 Type 3 EIF 4 EXT 5 Auth 6 Res/D/N/DC 7 Albania 25-X-2013 A 24-XII-2013 Res 10,12 Antigua and Barbuda 1-V-1985 Su 1-XI-1981 Armenia 1-III-2007 A 30-IV-2007 Res 10,12,13 Australia 22-IX-1986 A 21-XI-1986 D 17 Austria 5-X-1961 28-X-1963 R 5-I-1964 Res 12 Belgium 10-X-1968 20-X-1971 R 19-XII-1971 Res 10 Bosnia and Herzegovina 23-VIII-1993 Su 6-III-1992 Botswana 18-XI-1968 A 17-I-1969 Res 1,8 Brunei Darussalam 10-V-1988 A 9-VII-1988 China (the People's Republic of) C N Croatia 23-IV-1993 Su 8-X-1991 Denmark 5-X-1961 21-VII-1976 R 19-IX-1976 Estonia 13-V-1998 A 12-VII-1998 Res Eswatini 23-XI-1970 A 22-I-1971 Res 9 Fiji 28-VI-1971 Su 10-X-1970 Res 9 Finland 13-III-1962 24-VI-1976 R 23-VIII-1976 France 9-X-1961 20-IX-1967 R 19-XI-1967 D,Res 10 Germany 5-X-1961 2-XI-1965 R 1-I-1966 Greece 5-X-1961 3-VI-1983 R 2-VIII-1983 Grenada 20-V-1985 Su 7-II-1974 Ireland 3-VIII-1967 A 2-X-1967 Israel 11-XI-1977 A 10-I-1978 Italy 15-XII-1961 Japan 30-I-1964 3-VI-1964 R 2-VIII-1964 Lesotho 1-VI-1977 Su 4-X-1966 Luxembourg 5-II-1968 7-XII-1978 R 5-II-1979 Res 1 Mauritius 24-VIII-1970 Su 12-III-1968 Montenegro 1-III-2007 Su 3-VI-2006 Netherlands (Kingdom of the) 17-III-1980 2-VI-1982 R 1-VIII-1982 1 Res North Macedonia 20-IX-1993 Su 17-XI-1991 Norway 5-X-1961 2-XI-1972 R 1-I-1973 Poland 3-IX-1969 A 2-XI-1969 D,Res 12 Portugal 29-IX-1967 Republic of Moldova 11-VIII-2011 A 10-X-2011 Res 9,10 Serbia 26-IV-2001 Su 27-IV-1992 D Slovenia 8-VI-1992 Su 25-VI-1991 South Africa 5-X-1970 A 4-XII-1970 Res 9,10,12 Spain 21-X-1976 11-IV-1988 R 10-VI-1988 Sweden 5-X-1961 9-VII-1976 R 7-IX-1976 Switzerland 9-IX-1970 18-VIII-1971 R 17-X-1971 Res 10 Tonga 10-VIII-1978 Su 4-VI-1970 Res 9,10 Türkiye 23-VIII-1983 A 22-X-1983 Res 9,10,12 Ukraine 15-III-2011 A 14-V-2011 Res 9,10,12 United Kingdom of Great Britain and Northern Ireland 13-II-1962 6-XI-1963 R 5-I-1964 10 D,Res 9 — Full contractingparties table — Checked: 2026-10-07

This is general guidance, not legal advice. The rules are simplified; confirm current rates and details with a lawyer.

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