Estate Law

International Estates: Assets in Québec and Abroad

Reviewed and approved by Me Mirabela Petrulian4 min read

Me Mirabela Petrulian, Notary

Founder, Groupe Synergie Notaires (2007) · Member of the Chambre des notaires du Québec

You have built your life between two countries. A home in Laval, perhaps an apartment inherited in Eastern Europe, a bank account in your country of origin, a family plot of land passed down from generation to generation. This patiently built estate deserves particular attention — not only for your own sake, but above all for those who will one day inherit it. When an estate includes assets spread across several countries, the challenges multiply. Anticipating this reality is offering your loved ones an invaluable gift: clarity.

When an Estate Plays Out Across Multiple Territories

Immigrant families and people from transnational communities living in Laval or the Greater Montréal area are often in a particular situation: their assets are not all in the same place, and neither are their legal ties.

Yet every state applies its own rules in matters of succession. What is provided for, recognized, or required in Québec will not necessarily be valid or sufficient in another country. The result: an international estate can quickly become a multi-speed succession, where steps pile up, timelines stretch, and loved ones find themselves managing parallel procedures within legal systems they are not familiar with.

Quebec law provides rules applicable to estates that include a foreign element — that is, an international dimension. But knowing that these rules exist is not enough. What matters is taking action before the situation arises.

The Role of the Quebec Notary: Essential, but Defined in Scope

In Québec, the notary plays a central role in the liquidation of an estate. They assist the liquidator, prepare the necessary documents, and ensure that assets located on Quebec territory are transferred according to the rules.

However, their mandate does not automatically extend to assets located abroad. For assets held in another country, it will often be necessary to call upon local professionals — notaries, lawyers, or their equivalents depending on the legal system in place — who will act in coordination with the steps taken here.

Why Is This Coordination So Important?

Without preparation, loved ones may find themselves simultaneously managing two distinct legal systems, in different languages, with documents that do not mutually recognize one another. This situation gives rise to considerable delays, unexpected costs, and, at times, conflicts among heirs over the distribution of assets.

Planning ahead makes it possible to clearly identify who will be responsible for what, and how the various steps can be coordinated without contradicting one another.

A Quebec Will Does Not Always Cover Everything

Many people believe that a will drafted in Québec is sufficient to cover all of their assets, regardless of where those assets are located. This is not always the case.

Under Quebec law, it may be useful — or even necessary — to provide for testamentary arrangements tailored to each territory involved. In certain countries, a local will drafted in compliance with local law will be more readily recognized and enforced than a foreign document, even an authenticated one.

Me Petrulian will explain the details during your consultation, according to your personal situation and the countries involved.

Quebec Documents Put to the Test at Borders

A Quebec notarial deed may need to be apostilled, translated, or legalized in order to be recognized as valid in another country. These administrative steps — often little known — take time and must be anticipated.

The apostille is an international certification that attests to the authenticity of a public document. Not all countries are party to the same conventions, and the requirements vary considerably. It is far better to discover this before the passing of a loved one, not after.

Planning Is Protecting

The best way to protect your loved ones from a complex international estate settlement is to act now. This involves a few concrete steps:

  • Taking stock of your assets in each country where you hold them, noting their nature, approximate value, and how they are held
  • Reviewing your existing documents — will, mandates, title deeds — and assessing whether they adequately cover your entire estate
  • Consulting a notary in Laval who is familiar with estates that have an international dimension, in order to build a coherent and tailored plan

Every situation is unique. A family originally from Lebanon, another from Italy or Romania — the applicable rules and the steps to be anticipated will not be the same. This is precisely why a personalized consultation is indispensable.

Consult Groupe Synergie Notaires

Do you own assets in Québec and abroad? Do not leave your loved ones to navigate this complexity on their own. Book an appointment with Me Mirabela Petrulian at the Groupe Synergie Notaires office in Laval to plan your international estate settlement with complete peace of mind.

📍 67 Boulevard Samson, Laval (Sainte-Dorothée), QC H7X 3E6 📞 (514) 399-1009 ✉️ info@gsnotaires.com

Disclaimer — This text is provided for informational purposes only. It does not constitute legal advice and is not a substitute for the counsel of a professional tailored to your particular situation.

This text is provided for informational purposes only and does not constitute legal advice. As each situation is unique, it is recommended that you consult a professional to obtain advice tailored to your particular situation.

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