An Estate Is Divided in Four Countries. One Heir Is in None of the Files.

A man dies abroad, wealthy, with assets in Germany, the United States, the UAE and France. Four processes open. In Tehran there is a child from his first marriage, and no file names him — usually not because anyone hid him, but because nobody abroad knows.

Reaching an entitlement is not one step. It is six. And in each country the wall stands somewhere else.

Being named at all

No system searches for an heir it has never heard of. Until someone puts him in the file, he is not there. This is the one stage no statute solves.

Proving the relationship

Foreign counsel usually asks whether the first marriage was registered. Wrong question. What creates the entitlement is parentage, and the document that carries it is the child's Iranian identity record, not a marriage certificate. Where that record is incomplete, a separate proceeding runs in Iran first, and it takes months.

Establishing the share — where the four stop looking alike

Germany: the estate court must satisfy itself as to the content of Iranian law. An Iranian heirship certificate alone will not do that.

United States: the wall comes earlier, at notice. An heir not named in the probate is not merely disadvantaged; distribution proceeds without him.

UAE: assets freeze on death, and everything turns on the document chain and the framework the court applies.

France: succession runs through the notaire, not a court, and one question decides the file — whether Iranian law provides a protective reserve mechanism for children. That is a question of Iranian law. The notaire cannot answer it.

Representation

An heir in Iran cannot appear in Frankfurt or at a Paris notary's office. An adult sends a power of attorney. A minor needs a guardian — and here the natural guardian is himself a competing heir. No foreign court or bank accepts that without an independent representative.

Documents, then money

An Iranian document has no effect abroad on its own: translation, certification, and a chain that differs for every destination. An established entitlement is still not money received. The paying bank asks for source of funds and beneficiary identity, and in US matters a further layer belongs to US sanctions counsel, not me.

Where I sit is the Iranian layer of the file: an opinion an estate court can rely on, an expert declaration, a certificat de coutume answering the question the notaire cannot — and the part of the work that must happen inside Iran. The local layer stays with local counsel.

An entitlement is one thing. Reaching it is six stages and four languages of proof. Legal entitlement is not the same as practical ability.

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