Can a will signed abroad revoke an existing will?

Separate wills limited to each jurisdiction

Estate planning practitioners describe separate wills that are limited to the assets in each jurisdiction. Separate wills of this kind are described as addressing conflicts between jurisdictions and giving a person's intentions effect in each one.

Practitioners also describe documents that specify which assets they cover as coordinating taxes across jurisdictions. Asset coverage is described as relevant to both revocation between documents and tax coordination.

Foreign jurisdictions and asset types

The effectiveness of a will for foreign assets depends on the foreign jurisdiction and on the type of asset. Foreign rules differ and may apply. Differences in foreign rules matter when a family member or asset is abroad.

Global wills and parallel probate

Estate planning practitioners describe one global will for an expatriate when a grant is recognised in the civil law jurisdictions involved. If a choice of jurisdiction is not possible, multiple wills may initiate parallel probate proceedings in more than one place.

Foreign wills and U.S. real estate

Trust and estate practitioners describe enforcing a foreign will in another country as complex. In one practitioner's experience, transferring U.S. real estate through a California Probate Court under a will made abroad involved headaches, delays, expense and complexity.

Practitioners also describe ownership methods that cause automatic transfer to heirs on death. These methods do not rely on the legal systems of multiple countries. Trust and estate practitioners describe using one will in place of multiple wills, because signing another will elsewhere can accidentally invalidate an earlier one.