Legal Question in Real Estate Law in California
Will a Living Trust executed and signed in the USA be honored in the Philippines? Does it need to go through probate?
3 Answers from Attorneys
It depends on what the law is in the Philippines. You should consult a lawyer who is licensed to practice law in the Philippines.
It might depend upon the law of the Philippines, but I think the location of the trust property may be a lot more meaningful than where the trustee resides. If the trust property consists of a house, a bank account, and some stocks and bonds in a brokerage account, and all three are in California, any dispute between, say, the trustee and a beneficiary, or between two beneficiaries, would probably be within the jurisdication of a California court, or at least would involve the application of California law. An individual beneficiary residing the the Philippines would be subject to local law as to taxes, etc. Wills, I believe, are enforced according to the local law of the jurisdiction in which they were executed.
You need to post in a forum that handles Phillipine law.