Heirs in two countries.

Passing on wealth is the only financial event that happens exactly once, and always at the worst possible moment to discover that something was missing.

When family, assets and tax residence fit within a single country, planning is difficult but familiar. When they cross borders, what changes is not the degree of difficulty, but the nature of the problem. There are now two sets of rules that were not written to work together, and neither yields to the other.

What tends not to cross over

Documents made under one jurisdiction often do not have the same effect in the other, or have only partial effect, or require a local procedure to be valid. Structures set up to solve a problem in one country can create reporting obligations in the other. And there is the order of events: until a proceeding is resolved, the assets may be unavailable precisely to those who depend on them.

That is why the conversation about cross-border estate planning starts with liquidity, not structure. Those who remain need accessible funds, in the right currency, before any discussion of how the estate is divided.

Planning that only works in one country is not planning. It is a bet on never changing countries.

Who this affects

More people than you might think. A child who studies abroad and decides to stay. A property bought overseas. An account opened during a period of work in another country and never closed. A spouse with a second nationality. None of these situations is unusual, and any one of them already puts the family in the category where jurisdiction matters.

The other side, which I also have a duty to point out

Not every family needs an international structure, and selling structure to those who do not need it is costly in money and in complexity. There are situations in which the right answer is to organize what already exists more carefully, document intentions clearly and revisit them with every relevant change.

The work here is not legal work: implementation involves attorneys and accountants with experience in the relevant jurisdictions, and Van Soldat Wealth coordinates that work rather than replacing it. My part is to make sure the question is asked ahead of time, not after the fact.