ARTICLE
24 September 2026

The US/Swiss Estate: Pitfalls And How To Avoid Them From A Swiss Legal And Tax Perspective

BK
Bär & Karrer

Contributor

Bär & Karrer is a leading Swiss law firm with more than 200 lawyers in Zurich, Geneva, Lugano, Zug, Basel and St. Moritz. Our core business is advising our clients on innovative and complex transactions and representing them in litigation, arbitration and regulatory proceedings. Our clients range from multinational corporations to private individuals in Switzerland and around the world. Most of our work has an international component. We have broad experience handling cross-border proceedings and transactions. Our extensive network consists of correspondent law firms which are all market leaders in their jurisdictions. Bär & Karrer was repeatedly awarded Switzerland Law Firm of the Year by the most important international legal ranking agencies in recent years.
Bär & Karrer is a leading Swiss law firm offering comprehensive legal advice and business solutions. Contact their Zurich office for expert assistance with your legal matters and general inquiries.
Switzerland Tax

STEP New England, Boston / Online

This presentation by TW and BLR examines US/Swiss cross-border estate planning pitfalls. It compares Swiss matrimonial property regimes with US approaches and contrasts universal succession under Swiss law with US special succession. The US/Swiss Treaty of 1850 and recognition of foreign trusts in Switzerland are discussed, noting that forced heirship rights prevail over trust firewall provisions. 

The tax section addresses limitations of the 1951 estate tax treaty and the 1996 income tax treaty. Several practical case studies illustrating common planning challenges round out the presentation.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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