The Law Office of JM Donnelly

​We live in an increasingly interconnected world. Rising affluence, increased mobility, and  growing globalisation have enabled people transcend their local neighbourhoods and interact and integrate with people, companies and governments of different nations. It is not uncommon for individuals to own holiday homes abroad, to operate bank accounts in offshore havens or to have investments in third countries. When a person dies owning assets in multiple jurisdictions, complex issues are liable to arise in administering the estate. 

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Conflicts of laws arise because different countries apply different connecting factors for determining the law to govern the administration of an estate. Relevant connecting factors in this regard are domicile, habitual residence, nationality and situs. Where a testator dies leaving assets in countries applying different connecting factors for determining the applicable law, the question necessarily arises as to how the conflicting rules are to be reconciled, harmonised and applied.

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Estates may be subject to double or multiple taxation. In certain cases Double Taxation Treaties may eliminate or mitigate the effects of double taxation.​

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We advise on all aspect of international estate planning. The services we offer are set out below.