Need to ensure my will is recognised by the US

Hi,

Sorry if a similar post on this topic has been made lately, I wasn't able to find one....

My husband and I just had wills set up in the UK.  DH is Australian and I am a US citizen.

Our UK solicitor who did our wills said that I might be able to find a US attorney who could register or otherwise file a copy of my UK will so that it is also recognised by the US (please note that I am not attempting to use any legal words here, I am merely paraphrasing the discussion).

Firstly, am I correct in believing that a UK will is not automatically recognised in the US?

Secondly, if I do need to take any action to make sure my will is recognised in the US, does anyone know of someone based in London who could help me with this?

Thanks in advance!

Generally speaking a foreign Will is recognised by US courts, as it will have been signed, dated & witnessed.

As you are both non-UK domiciled you may need specific tax advice to minimise UK tax both during lifetime & on death.

I hope that the lawyer included a QDOT clause in the Will since otherwise there will be US estate tax payable if you die first and leave assets over $60,000 to your non-US citizen spouse.

Please note that each US State has their own laws on probate, so the answer as to whether your Will can be probated in the US will depend slightly on which State(s) you hold assets in.