The Problem

Our clients often come to us frustrated. They’ve spoken with Portuguese attorneys who can’t give a clear answer about how their U.S. wills or trusts will work here, or who simply say, “just add a Portuguese will.” Parents worry about what would happen to their minor children in a country where they have no family. Retirees are confused when their banks refuse to accept transfer-on-death or pay-on-death beneficiary designations.

We are the only U.S. estate planning attorneys with offices in Portugal, focusing exclusively on serving American expats in this jurisdiction. There is a specific way cross-border estate planning must be done to ensure a plan functions under both systems, and that coordination is rarely understood locally.

This masterclass lays out the essentials, so Americans in Portugal can understand what their plans need in order to work on both sides of the Atlantic.

The Risk

When a Portuguese advisor simply adds a local will to a U.S. estate plan, the result is usually misalignment: two conflicting wills, double probate, competing executors, or children inheriting property prematurely under Portuguese law. Once those conflicts arise, they are difficult and costly to fix and may expose heirs to extended probate in multiple jurisdictions.

Portuguese attorneys are highly skilled in local matters, but few understand the structure and intent of U.S. estate planning: revocable trusts, pour-over wills, beneficiary designations, or incapacity documents. Areia Global is currently the only U.S. estate attorneys practicing in Portugal, and we designed this class to fill that knowledge gap.

The Masterclass

Cross-Border Estate Planning for Americans in Portugal explains how to create an estate plan that works across both jurisdictions: protecting family members, preventing multiple probates, and avoiding tax mismatches.

The program covers:

• How Portuguese forced-heirship rules interact with U.S. wills and trusts

• What happens when Portuguese law overrides American testamentary intent

• Key tools for incapacity and guardianship planning across borders

• Common drafting errors that lead to multiple probate or will contests

Participants finish with a clear understanding of how to align U.S. and Portuguese documents so their families are protected and assets transfer efficiently.

“I didn’t know how my U.S. plan would work once we lived in Portugal, and no one seemed to have any answers. This helped me figure out our next steps.”
- K.N., Cascais

Who It’s For

• Americans living in Portugal

• Families holding property or financial assets in both countries

• Advisors supporting U.S. clients with Portuguese connections

• Anyone wanting to prevent cross-border estate disputes

Why It Matters

Most Portuguese professionals view estate planning as optional. For Americans, it’s a critical risk area, because U.S. estate documents are only effective if they align with foreign law.

Understanding these differences before executing new documents prevents costly disputes, unnecessary probate, and family stress during administration.