National borders are becoming more and more porous in today’s world for international business and well to-do people. With the freedom to travel among countries never greater than it is today, Non-US Persons are frequently purchasing property in the United States. The same can be said about US citizens purchasing property in other countries. In addition to cultural differences, motor vehicle driving habits, physical environment, cooking of food, disability access, medical treatment, costs of medical services, and emergency services vary greatly. Even significant difference exist between close trading partners – Canada and US.
Because customs and laws of the various countries differ, planning for life changing events such as death or incapacity can be complicated when an individual owns real and personal (or what are commonly called movables or non-movables) in more than one country. A popular planning technique in one country is not recognized in other countries. In addition, countries have tax schemes that vary greatly and appear to randomly interlace exposing international persons to double taxation. At Crest Key, we guide our clients to an optimal position through the application of techniques such as drafting international wills, trusts when appropriate, structuring how title to property is held, and electing treaty positions so as to minimize expense, taxes, and difficulties after death.