Map cross-border estate issues against the Australian state's succession law
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- Table countries, likely grants, which state's succession law seems to apply (lex situs for immovables, lex domicilii for movables), tax flags and missing documents.
- What the lawyer must review
- Instruct a qualified local lawyer on foreign law in each country
- Treat the succession situs of digital assets and crypto as unsettled
- Get specialist tax advice on double death duty or estate tax in each country
- Check US federal estate tax, UK inheritance tax and the EU succession regulation where relevant
- Decide domicile as a legal conclusion, not stated residency; it decides the law for movables
- Confirm recognition of foreign wills under the state's Wills Act
- Check resealing of foreign grants, which differs by state and country
- Written for / version
- Australia versionAU
Rules that apply
The document starts from the task name. Change it if this piece of work is different.
Who does what
| Role | What they do |
|---|---|
| Assistance | Supporting preparation only. Potential support includes identifying points for review. Confirm the tool’s capability and permitted scope. Substantive advice, judgement and any restricted content remain with the responsible human. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Check the specialist’s assumptions, qualifications and limits. Obtain the relevant expert or specialist review before relying on a technical conclusion.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.