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"U.S. Wills"

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Scott Click to EMail ScottClick to view user profileClick to check IP address of the poster 27-Jun-00, 04:29 PM (GMT)
"U.S. Wills"
Are wills executed in the United States, particularly in Ohio, valid in Germany? The testator is a German citizen. If so, what law can I cite to to confirm this?
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RE: U.S. Wills, gd, 03-Jul-00, (1)
RE: U.S. Wills, Scott, 03-Jul-00, (2)
RE: U.S. Wills, gd, 03-Jul-00, (3)

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gd Click to EMail gdClick to view user profileClick to check IP address of the poster 03-Jul-00, 10:29 AM (GMT)
1. "RE: U.S. Wills"
The answer is probably yes. As the testator was a German citizen, rather than attempting to enforce an Ohio probate order, it might be easier to apply for an "Erbschein" in Germany, i.e. start full probate proceedings - provided the will meets German form requirements. For this, see my message on "wills" within the same discussion forum - a reply to "Will by Indian citizen domiciled in Germany".
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Scott Click to EMail ScottClick to view user profileClick to check IP address of the poster 03-Jul-00, 02:10 PM (GMT)
2. "RE: U.S. Wills"
Thank you for your prompt reply. I have one further inquiry with respect to German recognition of an Ohio will. If the testator were to remain in the US, yet dispose of some of his property in Germany vis-a-vis the Ohio will, what must his executor do to ensure the disposition of his German property is honored by the German authorities?
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gd Click to EMail gdClick to view user profileClick to check IP address of the poster 03-Jul-00, 08:35 PM (GMT)
3. "RE: U.S. Wills"
Once the heir has an "Erbschein", this is a normal sale of land under German law. In a nutshell, this requires the sale contract to be in notarized form, and registration of the sale with the local land registry (Grundbuchamt) in order to become effective.
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