Effectiveness of a Will in Another Jurisdiction

People are very mobile these days. A person may be from Brazil, work in Canada, and have property in the US. Such a person naturally wonders whether his will drafted and signed in Alberta will be recognized in other jurisdictions. Unfortunately, I cannot give a definitive answer to this question. A will drafted in Alberta is likely perfectly valid in the US. The reason for this is Canada and the US share a legal history that originates from the English common wills and estate planning http://www.russweninger.com/. Though different jurisdictions have different wills legislation, a will drafted with Alberta law in mind is likely acceptable in the various US states. Likewise, a , Calgary legal wills drafted in Alberta is likely acceptable in the UK, Australia, and in other similar English-speaking first world countries whose legal traditions are based on English common law.

That being said, the safest approach is to consult with a lawyer in any jurisdiction in which you own property to determine whether your will is sufficient for the legal requirements of that jurisdiction. The important point to realize is that the relevant law is the law of the area where you own property, not necessarily the law of the jurisdiction where you happen to die. If you own property is several jurisdictions, your will may have to comply with the laws of each of those jurisdictions. Alternatively, you may consider other forms of ownership, such as trusts and corporations that will allow you to avoid estate administration in certain jurisdictions.