One Death, Three Legal Systems, Three Very Different Answers

Who inherits your wealth is not a universal rule — it depends entirely on which legal system holds the pen. Take the same family, the same estate, and place it under Iranian, German, or U.S. law, and the outcome can look almost unrecognisable. The clearest way to see the difference is one question: how much freedom do you actually have to decide?

Iran — freedom limited to one third

This is the point most people miss. Iranian inheritance is not purely fixed. The law splits the estate in two: two-thirds is governed by fixed shares derived from Islamic law — predetermined proportions for defined heirs (spouse, children, parents), not a matter of choice. But the remaining one-third is yours: through a will, you may leave that third to whomever you wish — a specific heir, a non-heir, even a charity. So Iran grants real testamentary freedom — but capped at one third.

Germany — freedom with a floor

German law flips the emphasis. You may choose your heirs freely — but that freedom hits a floor: the Pflichtteil, a compulsory share guaranteeing close relatives (children, spouse, sometimes parents) a minimum, regardless of the will. It equals half of what they would have received under intestate succession. You can direct most of your estate — but cannot fully disinherit those the law protects.

United States — freedom almost to the end

U.S. law takes the opposite stance. In nearly every state, testamentary freedom is near-absolute: you may leave your estate to whomever you wish, even disinherit close family, with only narrow protections (a spousal elective share in many states; Louisiana alone keeps limited forced heirship). And notably, there is no federal inheritance tax — though federal estate tax can apply to larger estates.

Seen together, the three form a spectrum of freedom: Iran gives you one third, Germany gives you everything above a protected floor, and the U.S. gives you almost all of it.

Now place one family across all three

Here is where it stops being theoretical. Imagine an Iranian family with property in Tehran, a business in Germany, and a child who is now a U.S. citizen. On death, each asset can fall under a different logic — the Iranian two-thirds/one-third split for Tehran, the German Pflichtteil for the German estate, U.S. freedom (and estate tax) for the American side. A will valid in one may be partly inert in another. Heirs can be entitled under one system and excluded under the next.

The real lesson: cross-border inheritance is not one plan in three languages. It is three legal logics that must be made to work together — or they work against each other, at the worst possible time.

The question is never simply "what does the law say?" It is "which law, over which asset, for which heir?" That is where the real planning begins.

##Inheritance EstatePlanning IranianLaw GermanLaw CrossBorder ARIKEH