[WSBAPT] Referral to Munich attorney

[John Creahan]

Ken,
In general, I would recommend having two wills ("situs wills"), a Washington will solely for US property (real and personal), and a German will solely for German real property. He may need a French will as well.
Many European jurisdictions (including France) have forced heirship laws that dramatically impact the estate plan, so a German lawyer will generally prepare the German will.
If he is concerned about surviving the surgery and needs to execute his Washington will while overseas, I believe US embassies will notarize the will for a fee. You may also check on what you would need to get an apostile in Germany.
Hope this helps,
John


John Creahan
john at cairn-law.com<mailto:john at cairn-law.com>
1325 4th Ave., Suite 940
Seattle, WA 98101
206-621-5848
www.cairn-law.com<http://www.cairn-law.com/>
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From: wsbapt-bounces at lists.wsbarppt.com [mailto:wsbapt-bounces at lists.wsbarppt.com] On Behalf Of Guardhi at aol.com
Sent: Thursday, April 16, 2015 4:43 PM
To: wsbapt at lists.wsbarppt.com
Subject: [WSBAPT] Referral to Munich attorney

I have a German citizen that is married, resides in Washington state and has property here.  He is applying for US citizenship and also owns property in France and is in Germany awaiting surgery.  He wants to execute a will in Germany.  Whose law would the will be executed under?  I am thinking a will conforming to  Washington state law, executed at the embassy in Munich.  Any referral to a German attorney in Munich or direction would be appreciated.


Ken Luce
Tacoma, WA
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