The cross border family: Navigating conflicting legal systems

Families are more dispersed than ever, holding assets in multiple countries, living across jurisdictions, and confronting very different succession, tax and estate laws. The core challenge is that legal systems rarely align. What is valid in one country may be void in another; what is tax-efficient in one may trigger penalties elsewhere.

At Reckon, we view cross-border structuring as inherently a coordination exercise. To serve families effectively, we start by mapping all relevant jurisdictions and identifying the points of tension early.

Our role is to bridge local expertise, lawyers and tax advisors in each jurisdiction, under a fiduciary umbrella that ensures consistency in strategy and execution. We help structure entities, wills, and inter-jurisdictional agreements that remain operational across borders and over time, with flexibility to adapt to changing rules.

We lean on modern tools for secure document sharing, version control, audit trails and shared data platforms, but the substance always rests with specialist advice. Reckon’s strength is being an integrator and executor. Our goal is to make complexity manageable so that the family’s intentions, not conflicting laws, determine outcomes.

If you advise international families or manage cross-border estates, let’s collaborate. Reckon’s team can help align fiduciary execution with your legal and tax strategy, bringing order, clarity, and protection to global family wealth.