Practice areas Wealth and succession

International wealth and succession

When a family has assets, heirs or residence in more than one country, succession stops being a probate case and becomes a structural problem. We deal with it before it becomes a dispute.

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One asset, two legal systems: that is where succession can unravel.

Brazilian law applies to succession the law of the deceased’s last domicile. The country where the property, the account or the equity interest sits usually applies its own. The result is predictable: the same estate subject to two incompatible sets of rules, heirs in different jurisdictions and a probate that drags on for years.

We advise families, partners and family businesses on the structuring of their wealth and the organization of succession — holdings, wills, gifts, family agreements and governance — so that the transfer follows what the family decided, not what the conflict of laws dictates.

We also conduct probate proceedings and disputes when planning was not done in time, including with assets located in more than one country.

When to seek us
There are properties, accounts or investments outside Brazil
An heir lives, studies or works abroad
The family controls a company and the next generation is approaching
There is a second marriage, children from different unions or a stable union (união estável)
A change of tax residence of the asset holder
Offshore assets never reported to the Central Bank or the tax authorities
An ongoing probate involves assets in another country
What it covers
01

Structuring the estate

Family and asset holding companies
Choice of jurisdiction for investment vehicles
Trusts and private-interest foundations, with due analysis of their effects under Brazilian law
Segregation of personal and business assets
02

Succession planning

Wills and testamentary dispositions
Gifts with reservation of usufruct
Marital property regimes, prenuptial agreements and stable unions (união estável)
Protection of the forced heirship share
Conflict of laws between jurisdictions
03

Tax and regulatory aspects

ITCMD (inheritance and gift tax), including assets abroad
Taxation of offshore investments under Law 14,754/2023
Reporting of assets to the Central Bank and the tax authorities
Regularization of assets and tax residence
04

Family governance

Family protocol or family agreement
Family council and board of directors
Rules for heirs joining the business
Generational transition
Structuring and selection of a family office
05

Probate and disputes

Judicial and extrajudicial probate
Assets located in more than one jurisdiction
Recognition of foreign judgments
Succession of equity interests
Disputes between heirs and partners
How we work

Each structure is built with the specialist it requires: tax counsel for ITCMD and Law 14,754 matters, and a local correspondent in each country where the family holds assets. Coordination and responsibility remain with the firm.

Present the case
Who conducts it

Corporate law, courtroom practice and private banking experience.

This practice combines three competencies that rarely coexist in the same firm: corporate and international structuring, courtroom experience in probate and family disputes, and knowledge of how large estates are actually managed by banks and family offices.

When the case requires tax counsel, a valuation expert or a foreign lawyer, the professional joins the team — and the client keeps dealing with the person who studied the case.

Structuring

Corporate law and international transactions; comparative governance and the formation of structures in Brazil and abroad.

Courtroom

More than twenty years of courtroom practice in probate, estate division and family disputes before the Brazilian courts.

Private banking

Decades in wealth management and multi-family offices in Brazil, New York and Switzerland, at Vice President level.

Meet the professionals
Areas that usually come with it
Corporate and M&A Tax Litigation and arbitration International trade and foreign investment Nonprofit sector
Initial consultation

Family matters are handled in a private conversation.

The first conversation is with the responsible partner, under professional privilege, and serves to understand the composition of the estate and define whether and how we can help.

WhatsApp +55 11 99961-3544
WeChat 微信 Eduardo_Murray
Partner’s e-mail eduardo@murray-legal.com.br
Office Av. Brigadeiro Faria Lima, 3729 — 5th floor
São Paulo · SP · 04538-905 · Brazil

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