A client of mine with English domicile of origin but now long-term resident and domiciled in US wishes to make a will in England to deal with inherited property interests. The estate also includes a bank account in the Channel Islands.
Can it be safely assumed that a will executed in England in the usual English form will be recognised and admitted to probate in the Channel Islands?
Gibbons Solicitors Limited
With non-English domicile, I would say the relevant Channel Islands jurisdiction is likely to require an Affidavit of Law from the US State of domicile to confirm there’s no conflict of law in accepting the provisions of the English Will. It may be best to consult someone in the relevant jurisdiction, as the laws differ from island to island, and the Courts can be quite particular. I can refer you to a couple of names if that would help.
Depending on the precise circumstances, I have found the (legal) transfer of a CI bank account into the joint names of beneficial owner and intended beneficiaries to be a practical alternative to potential future reseal procedures.