The article “When common met civil” was published in the STEP Journal in March. The article was written by ALRUD experts Kira Egorova and Ekaterina Vasina in collaboration with Henry Mander, Partner of HARNEYS, and Matthew Howson, the associate of HARNEYS. The article presents a cross-border analysis of the main issues relating to estate planning for Russian residents with the British Virgin Islands.
Holding assets outside one’s country of permanent residence can complicate the generational transfer of wealth, and particular attention is required when the head of the family resides in a civil-law jurisdiction but his holding vehicles incorporated in a common-law one. Different legal systems have their own rules for determining applicable law and competent bodies, along with different approaches to succession and procedural requirements. The article focuses on the main issues of inheritance planning, preparing a will in accordance with the laws of the two countries, Russia and the British Virgin, implementing the testator's wishes, protecting the rights of weaker parties, such as compulsory heirs.
Society of Trust and Estates Practitioners (STEP) is one of the largest international associations combining such private wealth experts, as advisors, trustees, administrators, and representatives of family offices and investment funds. ALRUD is a member of STEP.