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International Inheritance Law
Inheritances in the USA, Canada, Italy and France
More and more often, inheritances have an international reference. Real estate in France, Italy or Spain, shares and company participations in the USA and Canada, bank accounts in Switzerland or Liechtenstein – this raises legal questions that can no longer be resolved under German law alone, even if the deceased was a German citizen.
First of all, the applicable law must be determined in accordance with the rules of private international law (IPR). In the European Union, Regulation (EU) No. 650/2012 (Inheritance Regulation, EuErbVO, EU-ErbVO) has applied since 2012. If the IPR leads to the applicability of the law of a third country, the law must be determined. In individual cases, this can also lead to several legal systems being applicable, for example Italian law for real estate in Italy, North American law with differentiation between the individual states for bank deposits and shares in the USA.
The determination of foreign law and clarification of all related legal issues at home and abroad is one of the main specialisations of our law firm. In addition, we have an extensive network of specialized law firms in almost every country in the world to be able to examine any special questions that may arise with regard to foreign law at short notice.
- Inheritance certificate proceedings in Switzerland
- Settlement of an inheritance in Canada
- Settlement of an inheritance in the USA
Please contact one of our inheritance law specialists for a non-binding and cost-free pre-evaluation:
Dr. Frank Schmitz
Dr. Frank Schmitz