Does your will cover money held outside of the country? Let's say you are American, you die and you wrote a will in the United States, but you don't have wills outside of the American jurisdiction, but have money in South Africa and Pakistan. What happens to the money located there? I am asking the question, because I read there's something called: Expatriate Will for Assets Held in Canada.

1 Answer 1


Not necessarily

The laws of each country will apply to the assets held in that country.

In some jurisdictions, inheritance is mandated by law and there is no freedom for a testator to determine who inherits what: Pakistan is one such jurisdiction. In Pakistan, if the deceased is a Muslim, then inheritance proceeds according to Islamic law and the will is irrelevant. If they are not a Muslim, then the law of their domicile jurisdiction applies - so for a resident of say, California, Californian succession law applies including following a will if one exists.

South African law recognises freedom of testation (subject to certain limits) so a foreign will will generally be followed.

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