Estate Planning for Expats & Globally Mobile Families

Paley & Prehn, PLC

Life across borders requires planning across borders. If you live abroad, hold assets in more than one country, or have family members with different citizenships, your estate plan needs to work in more than one legal system.

At Paley & Prehn, PLC, we design estate plans that are practical for globally mobile families. We work directly with attorneys across the United States and around the world to ensure that your estate plan will hold up wherever life takes you.

We don’t simply prepare documents. We coordinate. That means we map your U.S. estate and tax exposure, identify which foreign rules may apply, and then work with the right local counsel – whether in another U.S. state or another country – to confirm modifications and/or ask foreign counsel to prepare parallel documents so that each plan is valid in its own jurisdiction. Our role is to design the overall structure and keep the pieces connected; their role is to ensure enforceability under local law.

Why Cross-Border Coordination Matters

Without coordination, it’s common for cross-border families to end up with conflicting wills or probate proceedings in multiple countries. Beneficiary designations may not be valid abroad, and trusts that are effective in California may be ignored overseas. We structure the overall plan and work with attorneys worldwide to confirm that U.S. and foreign documents complement each other and avoid conflicts.

Special Issues We Help Address

For expats and internationally connected families, estate planning often involves:

• Mixed-nationality marriages, which may require specialized tax structures—Qualified Domestic Trusts (QDOTs) or other arrangements—to preserve spousal protections.

• Guardianship for children living abroad, where a court must ultimately approve the appointment and may scrutinize the choice of a non-U.S. citizen or non-resident. These cases can be complex, and we work closely with you and local counsel to structure the plan in a way that gives the best chance of achieving your wishes.

• Foreign-held real estate, which follows local law and may require coordination of wills or localized strategies.

• Compliance with U.S. estate and gift tax rules, even for Americans living abroad, as treaty status doesn’t eliminate U.S. filing requirements.

Every one of these issues is woven into a cohesive, coordinated plan—designed in the U.S., confirmed with local counsel, and implemented with cross-border foresight.

Our Approach

We begin by gaining a clear picture of your assets, family ties, and the jurisdictions involved. From there, we design a U.S. estate plan that serves as the foundation. At the same time, we coordinate with attorneys in the places where you live and where your property is located to ensure the plan is enforceable and practical. In many cases, this means preparing dual wills—one for the U.S. and one abroad—so that each document is effective without revoking the other.

Once documents are signed, we provide detailed funding instructions and checklists so implementation doesn’t fall through the cracks. And when circumstances change – such as moving to a new country, acquiring property, or a change in marital status – we update your plan and coordinate again with local counsel to ensure your documents remain effective in every relevant jurisdiction.

Why Clients Choose Us

At Paley & Prehn, PLC, we are committed to guiding internationally connected families with clarity, coordination, and trusted counsel across borders.

Our clients turn to us because we take the time to explain their options and design plans that reflect their real lives. We don’t stop at the signature page. We follow through, working with attorneys across the U.S. and internationally so that the plan actually functions when and where it is needed. The result is not just a set of documents, but a coordinated plan that gives clarity and peace of mind to families – wherever life takes them.