New rules have gone into effect in the European Union which will allow individuals to opt to use the inheritance laws of their nationality rather those of the country in which they died or created the will. Courts in the country the will is probated must follow the rule of law of the jurisdiction that was chosen in the will which is intended to smooth cross border inheritance. The law will apply to all who die after August 17, 2015 in member states except in Denmark, Ireland, and the United Kingdom.
See, New EU inheritance rules now in force, The Connexion, August 17, 2015.
Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.
