Cross-border estate — executor checklist
What an executor needs when the estate, the beneficiaries or the assets are in more than one country.
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What an executor needs when the estate, the beneficiaries or the assets are in more than one country.
The document pack
- The will, any foreign will, and the death certificate
- A schedule of assets by country, with the situs of each
- Valuations as at the date of death, in each currency
- Details of every beneficiary, with their country of residence
- Registered plan and pension documentation
- Any trust or company through which assets are held
- Prior years' returns for the deceased, in each country
- Bank and custodian contact details for each holding
Why each of these is asked for
Situs, not residence, decides which country can tax an asset in an estate — so the asset schedule is organised by location first. The beneficiaries' residences drive withholding on distributions, and no distribution should be made before clearance, because the representative can be personally liable for what is assessed afterwards.
Your next step
Send what you have and we will tell you what is missing. A complete pack is usually the difference between a filing that takes a fortnight and one that takes a season. Bring last year's returns and we will tell you what is missing.
Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
Where international tax accountant comes into this file
The search that brings most people to this page is international tax accountant. It is answered here for cross-border estate: what creates the obligation, which filings discharge it, and the fee agreed before the work starts.
What working with us on cross-border estate — executor checklist looks like
The quote comes from your documents
Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.
You deal with the person who did the work
The practitioner who prepared and reviewed your file is the one who answers the question about it.
One team, not two firms billing separately
You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.
Residence is tested, not assumed
Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.
Files that look like this one
Building an asset schedule by situs for an estate
An executor came with a list of accounts and properties organised by which bank held them. The estate had assets in three countries and beneficiaries in two. We rebuilt the schedule by situs instead, so that each asset sat under the country entitled to consider it, with a date-of-death value in that country's currency and the conversion source recorded. The engagement produced a schedule each jurisdiction's advisers could work from without recreating it, and identified two assets whose location had been assumed rather than checked.
An executor who paid beneficiaries before clearance arrived
A representative had distributed most of the estate within months of death, on the basis that the tax position looked straightforward. A later assessment in a second country said otherwise, and the money was with beneficiaries abroad who had spent it. We assembled the estate's full position, prepared the outstanding filings, and negotiated the terms on which the balance would be settled. The engagement produced a resolved liability and a payment arrangement. It is the case we cite whenever an executor asks whether a distribution can safely go out early.
Assets held through a company the will did not mention
An estate appeared to hold foreign real property directly. The title documents showed it was held by a company, and the shares of that company were the asset the deceased actually owned. The distinction changed which country could tax what, and it changed the valuation exercise from a property appraisal into a share valuation. We traced the ownership chain, obtained valuations at the right level, and set out the position for both jurisdictions. The engagement produced a documented ownership structure and a date-of-death valuation of the shares rather than the building.
Prior years left unfiled by the deceased in one country
The deceased had emigrated and had continued to hold assets in the country of origin without filing there for a number of years. The executor discovered this only when a custodian asked for tax documentation before releasing a holding. We reconstructed the missing years from custodian records and prior correspondence, filed them, and then dealt with the estate's own position on top. The engagement produced a complete filing history for the deceased in both countries, which was what the custodian and the clearance process both required.
Valuing an estate at the date of death in several currencies
An estate held listed investments, a property abroad and a private shareholding, and two countries needed values in their own currency. We obtained a formal valuation for the unquoted holding and the property, evidenced the listed positions from custodian statements, and converted every figure using a single stated rate source applied consistently at the date of death. The engagement produced one valuation schedule that both jurisdictions accepted, rather than two schedules prepared separately that would have differed and needed reconciling later.
Beneficiaries resident in different countries and the withholding that followed
An estate was ready to distribute to beneficiaries living in three countries, and the executor had assumed the same treatment for each. Residence drove the withholding, and the rates differed. We established each beneficiary's residence, identified where a treaty claim was available, and obtained the certification the claim required before any payment was made. The engagement produced a distribution schedule showing the gross entitlement, the withholding applied and the basis for it, which the executor could hand to each beneficiary and to the estate's accounts.
Two Wills, Two Jurisdictions, One Estate
A will drawn for one country can revoke another or fail to reach assets held abroad. The review checks how each instrument interacts with the other and where probate will actually be required.
Read how this one runsA US Filer Married to Someone Outside the System
Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
Non-Resident Canadian Tax
Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
