International Wills & Inheritance · 10 Countries
Situs-aware, forced-heirship-aware, probate-aware. Dual-will drafting, Brussels IV choice-of-law strategy, and cross-border tax framing for Thai nationals with overseas assets, foreign heirs of Thai estates, and expats resident in Thailand.
AI Quick Answer · Speakable
A cross-border testator should almost always execute one will per situs jurisdiction — a Thai will for Thai land, a local will for foreign real estate and brokerage — with a mutual non-revocation clause. Forced-heirship regimes (France, Germany, Louisiana) demand a Brussels IV or IPRG choice-of-law election; common-law systems (US, UK, AU, SG) demand attention to probate speed, elective share and CGT event K3. NYC Visa & Translation runs the full pipeline: drafting, notarisation, Apostille (post-25 December 2025), embassy legalisation, certified translation and Bangkok probate liaison.
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Frequently asked questions
Do I need a separate will for each country I hold assets in?
Yes — a single global will invites conflict of laws. Dual (or multi-) wills aligned to the situs of each asset (Thai land in a Thai will, US brokerage in a US will) shorten probate and reduce tax exposure. Always add a mutual non-revocation clause.
Must overseas heirs travel to Thailand to inherit?
No. A Power of Attorney signed and notarised abroad, then Apostilled (post-25 December 2025) or legalised through a Thai embassy, plus a certified Thai translation, allows a Thai lawyer to petition for an estate administrator and transfer assets on the heir's behalf.
Does Thailand levy an inheritance tax?
Yes — the Inheritance Tax Act B.E. 2558 (2015) applies 5% for direct descendants and spouses, 10% for others, but only on the portion above THB 100 million per beneficiary.
How exposed is a Thai heir to US federal estate tax?
A US non-resident alien decedent has only a USD 60,000 exemption on US-situs assets versus USD 13.6 M for a US citizen. Direct holdings of US real estate or US stocks in a personal account above USD 60,000 are taxed at 40%; foreign-corp or trust ownership mitigates this.
Which countries have the strongest forced heirship rules?
France (réserve héréditaire), Germany (Pflichtteil) and Louisiana are the strictest. Brussels IV (Regulation 650/2012) lets a Thai testator elect Thai law for EU-situs succession — but France's 2021 prélèvement compensatoire can still claw back from French real estate.
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