Translation for Inheritance Claims Abroad

Heirs in the US, estate abroad

When a relative dies abroad, or a US resident dies owning property abroad, the heirs deal with a foreign notary or court. The documents travel in both directions:

• Going abroad: US death certificates, birth and marriage certificates proving relationship, US wills and letters testamentary, powers of attorney for a local representative. Each usually needs an apostille from the issuing state and a translation into the local language.
• Coming back: the foreign heirship certificate or court order, the inventory, bank letters, property deeds and tax assessments, translated into English for US heirs, banks and the IRS.

Who may translate for the foreign side

Notaries and courts in many civil-law countries accept only translations by their own sworn translators, especially for documents that will change ownership of property. Ask the notary before ordering. We can still prepare the US side: state apostilles on New Jersey and other state documents, and English translations of what arrives from abroad so you know what you are signing.

Heirship certificates

Many countries prove who the heirs are with a document that has no US equivalent: a German Erbschein, a French acte de notoriété, a Spanish declaración de herederos, an Italian dichiarazione di successione (a tax filing) or a Mexican court ruling in a juicio sucesorio. We translate the document's name literally with the original in brackets and explain what it does, rather than calling everything "letters of administration".

Within the EU

For deaths since 17 August 2015, the EU Succession Regulation generally applies the law of the country where the deceased habitually lived, and lets the heirs obtain a European Certificate of Succession recognised across member states. A US citizen living in Spain may therefore have a Spanish-law succession, with documents in Spanish, even for property in Italy.

Bank accounts and pensions

Foreign banks and pension funds release funds to heirs on their own checklists, often a death certificate, the heirship document and identity documents of each heir. Ask for the checklist in writing and translate exactly what it lists.

Order of steps for US heirs

1. Ask the foreign notary, court or bank for its document list in writing.
2. Order certified copies of the US death certificate and relationship records.
3. Get state apostilles on each.
4. Have them translated by the translator the foreign office accepts, often a local sworn translator.
5. Have a power of attorney prepared if a local representative will act for you, notarized and apostilled in the US.