[WSBAPT] UNIDROIT Convention

[John J. Sullivan]

But as you say, if it meets the requirements of RCW 11.12.020 it should be admitted to probate here. Did decedent reside here at death? Can’t you open the dominant here and have them open an ancillary in AU to convey the property there?

John J. Sullivan

Sent from my iPad

> On Dec 28, 2020, at 8:57 AM, jbdolan at jbdolan.com wrote:
> 
> 
> Thank you, John.  That article is helpful.  This particular Will meets all of the requirements, except that instead of signing each page with her name, the testatrix initialed each page with her three initials. 
>  
> -jbd-
>  
> From: wsbapt-bounces at lists.wsbarppt.com <wsbapt-bounces at lists.wsbarppt.com> On Behalf Of John J. Sullivan
> Sent: Monday, December 28, 2020 8:33 AM
> To: WSBA Probate & Trust Listserv <wsbapt at lists.wsbarppt.com>
> Subject: Re: [WSBAPT] UNIDROIT Convention
>  
> Jonas: 
>  
> Just researched this a week or two ago at the front end to see whether I could rely on it to convey a U.S. client’s real property in Canada. 
>  
> Twenty-three states have adopted  Unfortunately, WA has not adopted the uniform law, although BC and OR both have. I think it’s something the Section should consider advocating. I will recommend a parallel will that deals with the BC property only and complies with its law. 
>  
> “Uniform International Wills Act.”
> 
> 
> https://www.americanbar.org/groups/gpsolo/publications/gp_solo/2011/april_may/estate_planning_withforeignproperty/
>  
> John J. Sullivan
>  
> Sent from my iPhone
> 
> 
> On Dec 28, 2020, at 7:40 AM, jbdolan at jbdolan.com wrote:
> 
> 
> Do any of you knowledgeable folks know whether the state of Washington or the USA signed onto the  UNIDROIT (International Institute for the Unification of Private Law) Convention in 1994 (or 1996)?
>  
> It is a long story, but the short version is we are dealing with a US citizen who lived and died in Australia, leaving a fill in the blank LWT that does not appear to comply with Australian requirements for an “international Will,” although I believe it would pass muster pursuant to Washington law.  (All assets, including real property, are in Australia.) The attorney in Victoria, Australia asked me if I could find out the answer to the question above.
>  
> Any thoughts would be appreciated.
>  
> Jim Dolan
>  
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