What you've built in India, preserved for family around the world.
Your children may be in London, Toronto, Dubai or Singapore. Your estate plan needs to work in every one of those places, not just in India.
Disclaimer
US
US federal estate tax
US citizens and US-domiciled residents can face estate tax of up to 40% on worldwide assets above the federal exemption. A correctly structured Indian trust can help keep inherited assets outside a US beneficiary's estate.
Tax on trust distributions
Distributions from a non-US trust to a US person are generally taxed as income or capital gain. The India-US treaty can help prevent double taxation, but it must be documented correctly.
FBAR and FATCA reporting
US persons with an interest in a foreign trust or account must file FBAR and FATCA declarations. We structure your trust to reduce reporting obligations and brief beneficiaries on their requirements.
Do I need to update my estate plan if my child becomes a US citizen?
Canada
No estate or inheritance tax
Canada has no dedicated estate or inheritance tax, a significant advantage for NRI families with Canadian beneficiaries.
Deemed disposition on death
Canada treats a deceased person as having disposed of all property at fair market value just before death, so a Canadian beneficiary's own estate later faces capital gains tax on any growth. Holding assets in trust can help defer or manage this.
Foreign trust reporting
Canadian residents receiving distributions from a non-resident trust must file an information return with the CRA. Non-compliance carries significant penalties.
Will my Canadian children need to report their inheritance to the CRA?
United Kingdom
IHT excluded property
Indian assets in a discretionary trust settled by a non-UK-domiciled person can sit outside the UK inheritance tax net. Positions vary and should be confirmed for your circumstances.
Long-term resident rules
Recent UK reforms treat someone UK-resident for a set number of the last twenty tax years as a long-term resident, which can bring their worldwide estate into UK IHT. We track this for every UK-resident beneficiary and confirm the current rule at the time of planning.
India-UK double taxation agreement
The India-UK treaty can prevent UK residents being taxed twice on trust income that has already borne Indian withholding tax.
How long do I need to live in the UK before my worldwide estate is taxed there?
United Arab Emirates
No personal tax
The UAE has no personal income or inheritance tax, making it one of the most favourable jurisdictions for NRI beneficiaries.
UAE succession law
Despite the tax simplicity, non-Muslim expats face a real succession law risk. UAE reforms allow wills to be registered at DIFC or ADGM Courts, applying home-country law, but this needs to be addressed separately from your Indian plan.
FEMA on India-to-UAE remittances
Remittances follow the same FEMA framework as other cross-border distributions. NRI status affects the treatment for UAE residents who are also Indian citizens.
Is a UAE will enough to protect my children who live there?
Australia
No inheritance tax
Australia has no federal inheritance or estate tax.
CGT on inherited foreign assets
The cost base for Australian CGT is generally the market value at the date of death, with later appreciation taxed in Australia. Trust distributions can be treated differently.
Foreign trust reporting
Australian residents receiving benefits from a foreign trust must report to the ATO. We advise beneficiaries on their obligations.
Will my Australian children pay tax when they inherit?
Singapore
No inheritance tax
Singapore has no estate duty; inherited assets generally arrive free of Singapore tax.
Income tax on trust distributions
Singapore does not tax capital gains, and foreign-sourced income is generally exempt, making it one of the more favourable locations for trust beneficiaries.
India-Singapore tax treaty
One of India's more favourable treaties, with reduced withholding on dividends, interest and royalties for Singapore-resident beneficiaries.
Is Singapore a good place for my children to receive an inheritance?
FAQs
Do I need an Indian will if I already have one in my country?
What is the difference between a will and a trust?
My children are in different countries. Can one plan cover all of them?
What is FEMA and why does it matter?
Is it too late to set up a trust if my parents are elderly?
Does anyone need to travel to India to set this up?
Can you help pass on a family business, not just personal assets?
Real insights. Real people. Real results

Case Story: A private family trust across three continents
Coming soon

Legal Update: Cross-border estate planning after a UK ruling
Coming soon

Expert Insight: The gap a will alone leaves behind
Coming soon
Est. 2000 · 26 years
Over USD 1 billion in property and estate matters handled
Offices in the UK, Canada and the US
Legal and execution teams across India
Clients in 45+ countries
Protecting what you've built shouldn't stop at the Indian border.
