Celebrity Estates: Cross-Border Estate Planning Lessons with Martin Behn

Estate planning becomes more complicated when assets, citizenship and tax rules extend beyond a single country. What seems straightforward on paper can quickly involve multiple jurisdictions, reporting requirements, and competing legal systems.

In this episode of Celebrity Estates, Senior Editor David Lenok speaks with Martin Behn, partner at Lathrop GPM, about the estate planning challenges that arise when individuals hold assets or citizenship in more than one country. Using the recent death of actress Catherine O’Hara as an example, Martin explains how advisors must identify assets globally, determine which country’s laws apply, and account for international tax treaties.

David and Martin also explore how factors like residency, citizenship and domicile influence estate taxation and inheritance outcomes. Their conversation highlights why cross-border planning often requires coordination between advisors and attorneys in different jurisdictions to help families transfer wealth effectively.

Key takeaways:

• Why identifying every asset worldwide is the first step in cross-border estate planning
• How tax treaties determine which country controls estate and gift tax treatment
• Why advisors may need estate planning documents in multiple jurisdictions
• The planning risks when countries impose forced heirship rules on estates
• The difference between citizenship, residency and domicile in tax planning
• And more!

Resources:

• Listen to Celebrity Estates on Wealth Management
• Subscribe and listen to Celebrity Estates on Apple Podcasts
• Subscribe and listen to Celebrity Estates on Spotify
• Trust and Estates Magazine

Connect With David Lenok:

• david.lenok@informa.com 
• Wealth Management
• LinkedIn: David Lenok
• LinkedIn: Informa
• LinkedIn: Wealth Management

Connect With Martin Behn:

• LinkedIn: Martin Behn
• Website: Lathrop GPM

About Our Guest:

Martin Behn represents clients in matters concerning estate planning, trust administration, probate, and trust litigation. Martin’s practice primarily focuses on estate planning with a multi-generational focus. 

Martin advises clients regarding sophisticated family wealth transfer and tax planning techniques, including Grantor Retained Annuity Trusts (GRATs), Charitable Remainder Trusts (CRTs), sales to intentionally defective grantor trusts, gift trusts with intentionally defective grantor trust provisions, Irrevocable Life Insurance Trusts (ILITs), and Generation-Skipping transfer Trusts (GST / Heritage Trusts).

Prior to joining the firm, Martin was with Sinsheimer Juhnke McIvor & Stroh, LLP in San Luis Obispo, California, and Grant & Gordon, LLP in Palo Alto, California.