Using trusts and international wills is a key strategy to safeguard assets and streamline estate planning for expats in 2026.
With changing estate, gift, and generation-skipping tax rules, as well as cross-border compliance requirements, careful planning is more important than ever.
Questo articolo analizza:
- What is the maximum amount you can inherit without paying Inheritance Tax in 2026?
- What is the best way to leave property to your children in 2026?
- What does a trust do compared to a will?
- Is there generation-skipping tax exemption in addition to the estate tax exemption?
Punti di forza:
- Trusts with cross-border wills give expats control and privacy.
- US estate, gift, and GST exemptions rise in 2026; other countries vary.
- Cross-border planning limits probate delays and inheritance taxes.
- Structured trusts ensure smooth, multigenerational wealth transfer.
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Le informazioni contenute in questo articolo hanno un valore puramente indicativo. Non costituiscono consulenza finanziaria, legale o fiscale e non rappresentano una raccomandazione o una sollecitazione a investire. Alcuni fatti potrebbero essere cambiati dal momento della stesura.
What is the estate plan for the future?
The estate plan for the future centers on structures that remain valid across borders, reduce exposure to conflicting inheritance laws, and protect assets from probate delays.
For expats, this means prioritizing international wills, revocable and irrevocable trusts, and planning that accounts for tax residency changes.
It also includes digital estate planning, powers of attorney that work abroad, and clear succession instructions for offshore accounts, global real estate, and business holdings.
The future of estate planning emphasizes mobility.
More expats are choosing flexible structures that reduce the risk of forced heirship in civil law countries, minimize taxation in high-tax jurisdictions, and simplify the transfer of assets to heirs living in different countries.
Privacy also plays a growing role, making trusts and insurance-based structures increasingly attractive.
What is the best way to plan your estate in 2026?
The best way to plan your estate in 2026 is to combine a cross-border will with a trust-based structure that works internationally.
Expats often face conflicting inheritance rules because assets may be governed by the country where they are located rather than the country of residency.
A global estate plan ensures consistency, legal enforceability, and tax efficiency.
In 2026, effective estate planning strategies for expats include:
- Cross-border wills – Ensure your will is recognized in multiple jurisdictions to prevent conflicts.
- Trust-based structures – Use discretionary or revocable trusts to manage assets and provide flexibility across borders.
- Life insurance for liquidity – Cover inheritance taxes, probate costs, or mandatory court obligations in certain countries.
- Private placement life insurance (PPLI) – Offers tax-efficient investment and estate transfer options for high-net-worth individuals.
- Foreign grantor trusts – Useful for managing offshore assets while maintaining control and potential tax advantages.
- Tiered asset-holding companies – Organize assets across multiple entities to simplify generational transfers and reduce exposure to local probate rules.
- Regular treaty and tax reviews – Stay compliant with tax treaties and evolving inheritance or gift rules in your countries of residency and citizenship.
- Succession planning for digital assets – Include cryptocurrency, NFTs, and online accounts in your estate plan to avoid loss or inaccessibility.
What’s more powerful than a will in 2026?
In 2026, a fiducia remains more powerful than a will for most expats.
A will only takes effect after death and typically triggers probate, which can be slow, public, and complicated when multiple countries are involved.
A trust, by contrast, operates during your lifetime and continues afterward, allowing uninterrupted management of global assets.
Trusts also bypass probate, offer privacy, help address forced heirship issues in many jurisdictions, and give you greater control over how and when beneficiaries receive assets.
For high-net-worth expats with businesses, investments, and international property, a trust retains a clear advantage by providing stability, asset protection, and smoother cross-border execution.
Is it better to have a trust or an estate in 2026?
In 2026, it is generally better to have a trust rather than relying solely on an estate.
An estate only exists after death and becomes subject to each jurisdiction’s probate and inheritance rules, which can be inefficient for expats with assets across borders.
A trust continues to offer more control, privacy, and international flexibility because it can hold and manage assets while you are alive.
Expats also gain the benefit of structuring trusts in tax-neutral jurisdictions, reducing exposure to double taxation and ensuring continuity if the grantor relocates.
An estate is still relevant for distributing personal items and naming guardians, but a trust remains the more effective vehicle for long-term wealth transfer.
What is the estate exemption for 2026?
In the US, the estate exemption for 2026 is USD 15 million per person under the new OBBBA law.
Before 2026, the exemption stood at USD 13.99 million per person, with a planned reduction to around USD 7 million due to the TCJA sunset provision.
The generation-skipping transfer (GST) tax exemption matches this amount, while the federal estate tax rate above the threshold remains 40%.
For other jurisdictions, estate exemptions vary widely.
The UK, for example, maintains a nil-rate band of GBP 325,000, while countries such as France, Germany, and Japan apply progressive inheritance taxes with thresholds and rates depending on residency, asset location, and family relationships.
Expats should be aware of both local exemptions and double-taxation treaties when planning cross-border estates.
What is the generation skipping tax exemption in 2026?
In the US, the generation-skipping transfer (GST) tax exemption for 2026 is also USD 15 million per person, matching the estate exemption but applying to a different type of transfer—those that skip a generation.
GST tax is a separate layer of tax designed to prevent bypassing estate tax by transferring assets directly to grandchildren or other skip persons.
Prior to 2026, the GST exemption was USD 13.99 million, with a planned rollback before OBBBA reversed it.
Conclusione
Estate planning for expats in 2026 requires more precision than in previous years, especially with tax thresholds shifting and cross-border rules tightening.
Whether you hold assets in one country or several, the most effective approach is one that anticipates change, adapts to different legal systems, and ensures continuity for your heirs.
Trusts, international wills, and updated tax-efficient structures remain the foundation of a resilient global estate plan—one that protects your wealth today and keeps it accessible for the generations that follow.
Domande frequenti
What is the biggest mistake with wills?
The biggest mistake with wills is assuming one will works everywhere.
Many expats rely on a single will that fails to meet legal requirements in the countries where their assets are located.
This can cause probate delays, invalidation, or conflicts with forced heirship laws. Separate wills per jurisdiction or an international will drafted by cross-border specialists avoid these issues.
What is the 7 year rule for inheritance?
The 7 year rule for inheritance usually refers to the UK rule where gifts made more than seven years before death are exempt from inheritance tax.
For expats with UK ties, this rule influences lifetime gifting. Gifts made within seven years may still be taxable, depending on the value and timing.
What is the 2 year rule for inheritance?
The 2 year rule for inheritance applies in some jurisdictions, like the UK, for qualifying business or AIM-listed investments.
If held for at least two years and still owned at death, they can pass to beneficiaries free of inheritance tax. Regular assets like cash or real estate do not qualify.
Who gets the income from a generation-skipping trust?
The income from a generation-skipping trust is typically directed to the beneficiaries designated by the grantor, often grandchildren or later generations.
Some structures allow children to receive income while preserving principal for younger heirs.
The trust deed determines how income is distributed, ensuring long-term wealth preservation across multiple generations.
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Adam è un autore riconosciuto a livello internazionale in materia finanziaria con oltre 830 milioni di visualizzazioni di risposte su Quora, un libro molto venduto su Amazon e un contributo su Forbes.
