In this episode of Swiss Money Secrets, WHVP’s Jess Roberson and Jamie Vrijhof-Droese welcome Daniel Gabrieli, Partner at Wenger Plattner, for an in-depth discussion on how Swiss inheritance law affects U.S. citizens. Together, they unpack one of the most fascinating—and often overlooked—areas of cross-border planning: the legal framework governing inheritance between the United States and Switzerland.
At the heart of the conversation is the oldest cross-border agreement in Swiss history that remains in force today, a treaty that continues to shape how inheritance cases are resolved when assets, heirs, or testators span both countries. Daniel provides expert insight into why this agreement still matters, how it is applied in practice, and what U.S. citizens living in Switzerland (or holding Swiss assets) need to understand to avoid costly surprises.
Listeners will gain clarity on common misconceptions, real-world planning challenges, and the key considerations that arise when U.S. and Swiss inheritance rules collide. Whether you are an American expat, an advisor working with international families, or simply curious about how centuries-old treaties still impact modern wealth planning, this episode offers practical guidance and valuable perspective.
00:00 Intro
00:29 Swiss cash initiative hitting the ballot box
05:05 Introduction to Daniel Gabrieli
08:07 What happens with real estate assets and other assets of a U.S. person in Switzerland when they pass away?
10:03 The oldest treaty between the U.S. and Switzerland concerns Friendship, Commerce, and Extradition.
12:51 How are bank accounts handled in the present day?
15:58 U.S. Inheritance Law vs. Swiss Inheritance Law: the choices that are there for Americans
29:15 Forced Heir-ship Laws in Switzerland
31:46 Can Trusts own real estate in Switzerland?
34:10 Final thoughts
46:07 Outro
📞 Contact Daniel Gabrieli, Partner at WengerPlattner
Email: daniel.gabrieli@wenger-plattner.ch
Telephone: +41 43 222 38 00
Website: https://wenger-plattner.ch/en/team/gabrieli-daniel/
LinkedIn: https://www.linkedin.com/in/daniel-gabrieli-7b397a214/
📞 Contact WHVP
Website: https://whvp.ch/ Email: info@whvp.ch
Telephone: +41 44 315 77 77
Schedule a Meeting: https://whvp.ch/get-started
ℹ️ About WHVP WHVP is not just another asset manager. We are an independent firm specializing in managing the funds of private clients. Registered with the SEC in the U.S. and located in Zurich, Switzerland, we are associated with several first-class private banks in Switzerland and Liechtenstein, which serve as custodian banks for our clients' accounts. Our asset management principles are rooted in conservative, long-term-oriented capital preservation strategies. We prioritize personalized service, crafting portfolios that are shielded against U.S. Dollar depreciation while leveraging overseas investment opportunities.
Disclaimer: All posts and publications are for your information only and are not intended as an offer, promotion, or solicitation to buy or sell any financial instrument or perform any other financial transactions. All information and opinions expressed in posts and publications reflect our current views as of the date of the publication and may be liable to change without notice.
