wiki / Succession Planning: Wills, Multi-Jurisdiction & Forced Heirship

Succession Planning: Wills, Multi-Jurisdiction & Forced Heirship

Concept

Succession planning is the advance design of how capital will pass to the next generation. For an international family, it is not a single document but a system of coordinated decisions: applicable law, forced heirship, taxes, structures, documents and continuity—aligned across all countries where the family has assets and ties.

Succession is determined by the location of the asset (situs) and the ties of the deceased, and a single will cannot cover it all. This page is a domain map: from here you can navigate to any of the topics below.

🍓 Succession planning is a system of six layers: applicable law, forced heirship, taxes, structures (foundations and trusts), documents and continuity. A weak link in any of them destroys the entire plan.

Law and Conflicts

🔗 Related
Applicable Law and Brussels IV · Forced Heirship · Domicile and Residence · Recognition of Trusts (Hague) · European Certificate of Succession · Intestate Succession under Russian Law

Where it all begins: which law governs succession and where forced heirship applies. Domicile and citizenship determine both the applicable law and the recognition of foreign structures—so conflicts are resolved before choosing instruments.

Instruments: Foundations, Trusts, Holdings

🔗 Related
Russian Personal/Succession Fund · Private Foundations · How Trusts Work · Types of Trusts · Trustee and Protector · Private Trust Company · Asset Protection Trusts · Family Holding · Family Office

The core of the plan is structures that separate ownership from benefit. They outlive the testator and hold assets under uniform rules; the choice of vehicle depends on whether it is common law or civil law, and where the beneficiaries are located.

Inheritance Taxes

🔗 Related
Inheritance Tax Map by Country · US Estate Tax and US-Situs · UK IHT and Trusts · Gift Tax · Trusts and CFC (Russian Beneficiaries)

Inheritance tax is highly uneven: in some places there is none, in others the rate reaches tens of percent, and a separate trap is US-situs assets of a non-resident. The route depends on the family's jurisdictions and the regime for Russian beneficiaries.

Documents and Process

🔗 Related
Wills and Probate · Russian Inheritance Contract · Incapacity Planning · Minor Heirs and Guardianship

Intent is embodied in documents—a set coordinated across all jurisdictions: wills and the procedure for their recognition, inheritance contracts, incapacity plans and guardianship of minors.

By Asset Type

🔗 Related
Business Succession · Foreign Real Estate · Foreign Accounts and Portfolios · Life Insurance · Crypto and Digital Assets

Each asset is inherited differently: a business requires a succession plan, real estate—law of the place where it is located, accounts and portfolios—access and currency rules, and crypto—a pre-resolved question of keys.

Family and Governance

🔗 Related
Family Charter · Family Office

Capital survives generations only with rules: governance sets who makes decisions and how, and structures execute them.

⚙️ A succession plan is not a one-time document but a living system: it is reviewed with every major change in the family—marriage, birth, relocation, sale of a business.
💡 A quick assessment of your situation by country and assets is provided by the Legacy Navigator.

This material is for reference purposes and does not constitute individual legal advice.


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