Many individuals hold bank accounts in different jurisdictions
like England, Jersey, Singapore and Dubai. These accounts are part
of the individual's assets and will form part of their estate
on death. A recent judgement in the Jersey courts highlights the
importance of knowing the foreign rules when transferring cash in a
foreign bank account.
Bank accounts are considered 'movable assets'. This
means that the money in that account must be distributed in
accordance with the inheritance laws of the country where the
deceased had their domicile (permanent home country). If an
individual is domiciled in England, the English courts would uphold
an English Will of worldwide movables ( foreign bank accounts).
However, getting those foreign banks and courts to obey the English
court order is not always easy.
