Areas of practice
International inheritance law
Thorough estate planning and legally sound cross-border arrangements: We advise private individuals, families, and business owners on international inheritance law and inheritance disputes with a focus on German-American inheritance cases, complex asset structures and international tax and estate planning.
Inheritance law
International inheritance law places the highest demands on planning, structure, and legal precision. Different legal systems, forced heirship rules, tax consequences, and divergent estate settlement procedures can significantly complicate estates. This is especially true for assets such as real estate holdings or business interests abroad.
We develop clear succession planning strategies between Germany, the USA, and other jurisdictions.. Our advice ensures that assets are transferred efficiently and that family interests are protected — in a way that is durable, legally sound, tax-optimized, and internationally enforceable. We cover everything from simple wills to comprehensive international estate plans.
A special focus is on affluent individuals, business families, and internationally mobile high-net-worth families with, assets and multiple countries. We advise specifically on estate structures with connections to Germany, the USA, the EU, the United Arab Emirates, and South America.
On request, we will coordinate the legal estate planning with Tax advisors, Family Offices, Asset managers, foreign law firms and other advisors. Legal advice remains clearly separate from investment or asset advice. The goal is a legally sound structure that combines asset protection, tax planning, succession, testamentary intent, and practical implementation.
Overview of our services
Inheritance tax Germany and USA
Tax-optimized transfer of assets and company shares, taking into account both tax systems.
- Analysis of the tax implications of cross-border estates
- Design to avoid double taxation and to utilize tax allowances
- Structuring Lifetime Gifts
Advice on Gift Tax, Estate Tax, and German Allowances
International estate settlement
Efficient, legally compliant processing of estates with assets in multiple countries.
- Assistance with International Estate Settlement (Probate, Certificate of Inheritance, Letters of Administration)
- Representation before US probate courts, banks, authorities, and tax offices
- Enforcement of compulsory portion claims across borders
- Coordination of international assets (real estate, financial investments, and company shares)
US Trusts in an International Context
Asset protection, tax advantages, and clear succession planning across generations.
- Establishment and evaluation of trust structures for estate planning
- Settlement of Trusts under German Family and Inheritance Law
- Assessment of Tax Implications and Compliance Risks
- Consultation on revocable, irrevocable, family trusts, living trusts, and international asset protection structures
German and US Wills and Powers of Attorney
Uniform estate-planningdocuments that are recognized and enforceable in both legal systems.
- Design and review of will and estate planning under German and US law
- Creation of unified or separate wills for multiple jurisdictions
- Legally Sound Drafting of Powers of Attorney (Germany/USA) to Avoid Estate Settlement Roadblocks
- Coordination with Notaries, Executors, and Estate Planners in the USA
International inheritance matters deserve careful and proactive advice.
In international inheritance law, we begin with a thorough analysis. Let's explore together which regulations are relevant to your situation.
International Inheritance Law
Sample Cases
The case examples presented are solely for the illustration of typical inheritance law issues in an international context. They are fictional, abstracted scenarios without reference to specific individuals or mandates.
Estate planning for assets in Germany and the United States
A private individual with German citizenship holds assets in Germany and the USA, including real estate and investments. The objective is to create a clear and internationally effective estate plan that safeguards family interests and minimizes tax burdens. The legal challenge lies in coordinating differing inheritance laws, mandatory inheritance shares, and tax consequences. Based on this, a structured international estate plan will be developed, encompassing both testamentary provisions and advance directives.
International Estate Settlement with US Probate Proceedings
Following the death of a testator with assets in multiple countries, heirs must settle the estate in both Germany and the US. In addition to applying for a certificate of inheritance, a US probate proceeding is required. The challenge lies in coordinating parallel proceedings, communicating with courts, banks, and authorities, and ensuring consistent asset management. The goal is an efficient and legally sound settlement of the estate across international borders.
Trust Structure in the Context of US and German Inheritance Law
A client is planning to incorporate a US trust structure for long-term asset and succession planning. This raises the question of how the trust can be reconciled with German inheritance, family, and tax law. The legal task involves assessing the civil and tax law implications, avoiding unintended mandatory heir's share or tax consequences, and ensuring compliance in both legal systems. On this basis, a viable structure will be developed that is legally sound and internationally coordinated.
International Inheritance Law
Frequently Asked Questions
Do you also support ongoing estate administration abroad?
Yes. We assist clients with the practical handling of international estates, for example with probate proceedings in the USA, applying for certificates of inheritance or letters of administration, as well as with communication with courts, banks, and authorities. The goal is a structured and as smooth as possible handling across national borders.
Does German or US inheritance law automatically apply?
No. Which inheritance law applies depends on various factors, such as the last habitual residence, nationality, or choice of law clauses made in the will. Without clear regulation, unexpected results can occur, especially in conjunction with mandatory share rights and different probate procedures.
Is it better to create a joint will or multiple wills?
This cannot be answered with a blanket statement. In some cases, a unified will that is recognized in multiple jurisdictions makes sense. In other situations, separate wills for different countries are the more legally secure solution. The crucial factor is that the provisions do not contradict each other and are internationally enforceable.
What needs to be considered regarding compulsory share claims in an international context?
Heirs' compulsory share rights differ significantly between legal systems. While German law recognizes mandatory compulsory share claims, the situation in US law is often structured differently. In international cases, it is therefore crucial to examine precisely whether and to what extent compulsory share claims exist and how they can be enforced or taken into account in estate planning.
What role do powers of attorney play in international inheritance cases?
Powers of attorney are a central component of estate planning. They can prevent accounts, real estate, or business decisions from being blocked in an emergency. International matters require powers of attorney that are recognized and practically manageable in the respective countries.
What role do trusts play in international inheritance law?
Trusts are a central instrument of estate planning in US law, but are not directly anchored in German law. Their establishment and use therefore requires special care. We advise on the design and coordination of trust structures with German inheritance and family law, as well as on tax implications and compliance issues.
Who is your international inheritance law advice suitable for?
Our consulting services are aimed at individuals, families, and entrepreneurs with international connections, particularly in German-American inheritance situations. Typical clients include individuals with assets in multiple countries, entrepreneurial families, or heirs seeking legal clarity and planning security.
Testimonials
Optimal solutions and careful post-processing
The law firm Urban Thier & Federer, P.A. was tasked with assisting me in settling my late wife's estate, following her passing in January of last year. Dr. Isabel Saulnier was assigned to me as the attorney handling my case. I am extremely satisfied with the quality of her work. Her accessibility, her ability to explain complex matters clearly and offer optimal solutions, her meticulous follow-up (even while on vacation), and her speed and flexibility were exceptional. Dr. Saulnier was consistently outstanding. In addition to her professionalism, she is also a very pleasant person to work with, which was particularly valuable during this difficult time. I have already recommended her services to a colleague at the French Consulate and will continue to do so whenever assistance with estate matters is needed.
A. S.
Corporate level in multi-million dollar construction projects
Urban Thier & Federer, P.A. is without a doubt the most professional law firm I have encountered in my career. Having primarily dealt with corporate-level lawyers on multi-million dollar construction projects, I have experienced in the UK that lawyers often forget who the client is. From the outset, John Urban made me feel comfortable, especially as this was a personal matter involving our own investment capital. John always made time for us, even outside of normal business hours, and his explanations were clear and concise on all points. He was supported by the efficiency of his extremely friendly team. We would recommend the firm and hire them again at any time. Thank you again.
H. D.
International Disputes
I've only had to deal with lawyers a few times in my life, but your firm seems to have an above-average standard, especially in that the entire, rather complicated process was explained in simple and understandable terms. At no point were my options or the next steps unclear to me. I wholeheartedly recommend UTF.“
T. S.
Further customer testimonials can be found on Google.
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International Inheritance Law
Articles & News
US Trusts and Offshore Trusts in International Estate Planning
International Estate Planning for High-Net-Worth Individuals Image Source: zhang In advising German clients with international assets, particularly those with connections to the USA, the question regularly arises as to whether a so-called US Trust or an offshore trust can be a suitable instrument for estate planning or asset protection. The answer is nuanced: a trust can be very useful, but […]
May 16, 2026
Cross-border estate planning – strategic, legally secure, coordinated
May 8, 2026
Recognition of an American Will in Germany
May 6, 2026
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