What are the main challenges of dual-jurisdiction estate planning?

Key challenges include: inheritance laws differ between jurisdictions, a will valid in one country may not be recognized in another, countries like the US and Japan impose estate taxes, and cross-border asset administration is procedurally complex.

Should I have separate wills for each country?

Yes. It is generally recommended to have separate wills for assets in each jurisdiction, each drafted according to local law. A coordination clause should prevent one will from revoking another.

What tax considerations apply to US-China cross-border inheritance?

US citizens and green card holders are subject to US estate tax on worldwide assets (2026 exemption ~12.92M per person, rates 18-40%). China has no estate tax.

Dual-Jurisdiction Wealth Succession Planning

Summary: High-net-worth cross-border families face unique challenges when planning wealth succession across two or more legal jurisdictions: legal conflicts, tax overlap, and complex procedures. This guide focuses on dual-jurisdiction estate planning between China and major developed countries.

Why Plan Ahead

Cross-border families face unique challenges with assets subject to different legal systems.

Will Planning

A valid will is essential. Chinese law recognizes foreign wills meeting certain requirements.

Related Reading: For a detailed guide on making a valid will for Chinese assets, see our Cross-Border Wills in China: A Guide for Overseas Chinese.

Trust Structures

Trusts can help manage wealth across borders effectively.

Key Considerations

Tax implications, document recognition, and currency controls need careful planning.

Dual-Jurisdiction Wealth Succession Planning

Why Plan Ahead

Will Planning

Trust Structures

Key Considerations

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