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

Who does what
RoleWhat they do
AssistanceSupporting 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.
LawyerPerform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use.

Checklist

  1. Check the specialist’s assumptions, qualifications and limits. Obtain the relevant expert or specialist review before relying on a technical conclusion.
  2. Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
  3. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  4. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

Related tasks

Related tools

Related jurisdictions