Regarding bequeathing the property, local law generally governs the transfer of real estate, whether during life or at death.
In the U.S., a will is the foundation of estate planning, “and we use revocable trusts to transfer real estate to friends and family,” Shier writes. “The rest of the world does not [always] play by these rules. Many civil-law countries do not have trust laws, which means that if you put foreign real estate into your U.S. revocable trust, it likely will have no meaning in the eyes of a foreign judge.”
American wills may also be ignored if they fall short of being properly executed under local law or conflict with local law. The foreign country may also impose gift, estate, inheritance or income taxes when you transfer your real estate.