Will this will work?

February 8, 2023 11:14 PM

YANML. Do you have experience with a US will that was also valid (OR NOT) in the United Kingdom AND Belgium (EU)?

Supposedly there's an international model law governing will provisions that's been adopted in several countries, including the UK and the US.

If you have personal experience of this one way or the other, I'd like to hear from you.

I could contact an international estates lawyer, and if you know of a reliable one, I'd like to hear about that too.

I'm looking to do as FEW wills as possible. I live in Spain and I know I have to do a will specifically for Spain, but I have assets in several different countries.

posted by Sheydem-tants to Law & Government (1 answer total)

Everything I have read suggests that you need to make a fresh application for probate on a US will in an English court, rather than a reseal. This means more paperwork and you probably need a US lawyer to do some tasks in relation to this as well as an English solicitor to help with the probate application. Do you also have assets in Scotland or Northern Ireland? Those are separate jurisdictions.

My experience is in resealing a will from Ireland into England and Wales, which was straightforward enough to do as the executor (although more hassle than it should have been). I wouldn't want to do this myself for anything more complicated.
posted by plonkee at 3:05 AM on February 9, 2023