Global Estate Planning for Canadians with Foreign Assets
Protecting your family—and your assets—across borders.
Because a Will that works in Canada might not work anywhere else.
What is Global Estate Planning?
It’s planning for what happens when your life crosses borders.
A standard Ontario Will works if everything you own—and everyone you care about—is in Ontario. But that’s not how many Canadians live.
You might own a family property in France, a vacation home in the Caribbean, or a U.S. investment account. Your children might live abroad. The moment your assets or heirs are outside Canada, your Will needs to do more than meet local rules. It needs to function in other legal systems, under different inheritance laws, tax regimes, and probate processes.
Global estate planning isn’t about complexity. It’s about making sure your plan actually works—wherever it needs to.
Do Canadian Wills Work in Other Countries?
Sometimes—but not always in a way that holds up when it matters.
Each country has its own inheritance rules, legal formalities, and probate process. Some recognize foreign Wills. Some don’t. Some require notarization. Some impose forced heirship rules that override your choices.
A Canadian Will might be ignored in Colombia unless it meets local formalities. Property in Mexico may require a notarized local Will to transfer cleanly. U.S. real estate often triggers its own probate process and tax considerations. In many civil law countries, the law restricts who can inherit and how much they receive—regardless of what your Canadian Will says.
If your plan doesn’t account for those differences, you may be leaving behind a legal mess. Even when a Canadian Will is technically valid, it can still trigger delays, added costs, or family confusion.
For some clients, the cleanest option is a separate Will that deals with foreign assets directly. In other cases, we keep everything in a single coordinated document—carefully worded to reduce conflict and minimize risk.
The right choice depends on your assets, the countries involved, and how much complexity you're willing to take on now to protect your family later. That’s why global estate planning isn’t a luxury—it’s a safeguard.
Are you an expat living outside Canada? You plan still follows you. If you're an expat Canadian living in Portugal, Dubai, or Thailand, your estate may still pass through Ontario law. Here’s what that means—and when to build a plan that works across borders.
→ Learn more about Wills for EU assets
→ Read FAQ: Do I need to update my Will if I move abroad?
Estate Planning for Assets Outside Canada
When you own property or have heirs in another country, your Canadian Will doesn’t automatically control what happens there.
Most countries apply their own local laws to property inside their borders. Real estate in France or Portugal, for example, is subject to local succession rules, including forced heirship. But if you’re a Canadian citizen, you can often choose Ontario law to govern your estate under the EU’s Brussels IV regulation. That option helps avoid heirship restrictions—but only if your Will is drafted properly, and that choice is clearly made.
Other countries—like Mexico or Brazil—don’t offer that choice. And even when foreign Wills are accepted, they often face delays, added court steps, or translation requirements.
The point isn’t that your Canadian Will is wrong. It’s that it might not work cleanly everywhere.
You may not need a separate Will for each country. But it does mean foreign assets and international family ties need more than boilerplate language.
How I Help Canadians Plan Across Borders
I don’t practice law in other countries—and I don’t pretend a Canadian Will will always work abroad.
What I do is help you build a Will that’s legally valid in Ontario and structured with your international situation in mind. That means identifying where the friction points are—based on what you own, where it’s located, and how foreign laws might affect with your plan.
In some cases, we draft a Will that’s intended to apply to your whole estate, including foreign assets—but with a clear understanding of the limits. In others, we restrict your Ontario Will to cover only Canadian property, or everything except assets in a specific country. When there’s a need for local legal input, I flag it—so you can decide if it’s worth pursuing.
This isn’t about overcomplicating your plan. It’s about being realistic, so your documents don’t fall short when it counts.
Cross-Border Estate Issues by Region
Every country has its own rules. Some will accept your Ontario Will with no questions. Others won’t. If you have ties to one of the regions below, it’s worth taking a closer look.
Europe (EU)
Many European countries impose forced heirship rules that restrict your freedom to craft your own estate plan. But under the EU Succession Regulation (Brussels IV), Canadian citizens can often choose Ontario law. That option needs to be handled carefully, and not every jurisdiction applies it the same way.
Learn more about Wills for EU assets →
United States
If you own U.S. property or have other U.S. ties, you may need a local Will to avoid probate delays or tax exposure. I help you understand when that step is necessary.
Learn more about Wills for U.S. assets →
Read the FAQ: Do I need a separate Will for U.S. assets? →
Other Countries
This includes the Caribbean, Latin America, Australia, and beyond. Some of these systems recognize foreign Wills. Others don’t. I’ll help you assess whether your Ontario plan is likely to hold up—or where it may need geographic restrictions and local counterparts. You don’t need a second Will unless the risk is high—but you do need a plan that doesn’t quietly fail.
Ready to Build an Estate Plan That Holds Up Globally?
If your life crosses borders, your estate plan needs to do more than check Ontario’s boxes.
You don’t need complexity for its own sake. But you do need a Will that accounts for what you own, where it is, and who it’s for without leaving gaps that turn into legal messes later.
Book a planning call to find out what needs to be fixed, what’s already working, and whether your current Will will actually hold up across borders.