Episode summary
Celebrity Estates: Cross-Border Estate Planning Lessons with Martin Behn
Summary
Cross-border estate planning gets complicated fast when a client has assets, citizenship, or ties in more than one country. Martin Behn says the first step is to identify every asset worldwide, then determine which jurisdiction controls each item and what reporting obligations follow. In the Catherine O’Hara example, the key issue is not the celebrity angle but the dual U.S.-Canada framework and the need to map property, taxes, and succession rules before death or administration creates problems.
Behn explains that tax treaties are central, but they do not solve everything. Real property generally follows the law where it sits, cash often tracks residency, and other assets may be governed by where they are held or located. If there is no treaty, he says advisors often need planning documents in that jurisdiction too, because a U.S. will or trust can be a blunt instrument abroad and some countries do not recognize trust-based planning the way the U.S. does.
He also stresses that citizenship, residency, and domicile are different concepts with different tax consequences. The conversation highlights how forced heirship rules, estate or inheritance taxes, FATCA, CRS, and sanctions screening can all change the outcome, making coordinated advice across jurisdictions essential.
Key takeaways
- Martin Behn says cross-border planning starts with a full inventory of assets, including bank accounts, retirement assets, real estate, and tangible property wherever they are located.
- Behn says U.S.-Canada treaties can determine which jurisdiction governs certain assets, but treatment still varies by asset class and by how the property is held.
- Behn recommends separate estate-planning documents in another jurisdiction when there is no treaty or when local law may not respect U.S. trust structures.
- Behn warns that forced heirship rules abroad can override a client’s wishes and can affect U.S. estate-tax outcomes.
- Behn distinguishes citizenship, residency, and domicile as separate tests that can point to different tax and succession results.
Notable quotes
“the US does have an income tax treaty with Canada. The US does have an estate and gift tax treaty with Canada”
“if I have clients with even even some modeicum of of assets in a different jurisdiction, usually my recommendation is you should at least have a simple will in that jurisdiction”
“citizenship is not determinative of where your doicile is and having residency for income tax purposes is not necessarily determinative of where your doicile is for estate and gift tax purposes as well”
How the episode opens
Welcome to the Celebrity Estates Wills of the Rich and Famous podcast. In this podcast, we break down high-profile celebrity estate planning cases for advisers and their clients. Most celebrity estate catastrophes are based on the same issues that everyday people face, just with the volume turned up.
Our goal is to identify and extract the individual estate planning issues that lie at the heart of each story. We then discuss what advisers should expect and how to avoid common pitfalls. Hosted by wealthmanagement.com senior editor David Leno.
Hello everyone and welcome to the latest episode of wealthmanagement.com celebrity estates wills of the rich and famous. For anyone new to the podcast in each installment myself and a guest take on a different celebrity estate and attempt to extract some key lessons that planners can apply to more traditional clients. The idea being that celebrity estate planning stories, although often ridiculous in their details, generally have at their cores very basic issues that can just as easily apply to nonf famous or fabulously wealthy clients.
To learn more about estate planning and how you can better serve your clients, visit wealthmanagement.com/trusts-states. Our monthly journal features tax law updates, wealth planning, retirement planning, and much more written by thought leaders in the industry. That's wealthmanagement.com/trusts-estates.
And we're joined today by Martin Bane. Martin's a partner at Lthrop GPM and he represents clients and matters concerning estate planning, trust administration, probate and trust litigation. Martin's practice primarily focuses on estate planning with a multigenerational focus.
He advises clients regarding sophisticated family wealth transfer and tax planning techniques including grant or retained annuity trusts, charitable remainder trusts, sales to intentionally defective granter trusts, gift trusts with intentionally defective granter trust provisions, irrevocable life insurance trusts, and generation skipping transfer trusts. Thanks so much for joining us, Martin.
From the episode’s captions: roughly the first two minutes, lightly cleaned. Keep watching on YouTube →
Topics
- cross-border estate planning
- tax treaties
- residency citizenship domicile
- global asset identification
- forced heirship rules
Companies and tickers mentioned
- Lathrop GPM
Watch the episode
Watch “Celebrity Estates: Cross-Border Estate Planning Lessons with Martin Behn” on YouTube
Summary, takeaways and quote selection by Octagon. Quotes are short excerpts; the full conversation is in the episode.
More from WealthManagement.com
-
The WealthStack Podcast: AI, Video and the New Rules of Client Engagement with David Moricca -
401(k) Real Talk Episode 216: November 11, 2026 -
The Planning Opportunities Hidden in High-Net-Worth Conversations -
Wealth Management Invest: Expanding Access to Private Markets with Blackstone’s Farhad Karim -
401(k) Real Talk Episode 215: November 4, 2026 -
How Advisors Can Use AI Without Losing the Human Relationship with Rron Rexha
WealthManagement.com, this episode and its artwork belong to their owners. Octagon is not affiliated with the show; this page is an independent summary.
