Bitcoin Estate Planning for Dual Citizens: US-UK, US-Canada, and Cross-Border Tax Traps in 2026

If you hold Bitcoin and carry passports from two countries, your estate plan is almost certainly broken. Not slightly suboptimal. Broken — in ways that could cost your heirs 60% to 80% of your Bitcoin holdings at death, depending on which two countries claim jurisdiction and how they decide to count.

The core problem is structural. The United States is one of only two countries on earth (Eritrea being the other) that taxes its citizens on worldwide income and worldwide estates regardless of where they live. If you're a US citizen living in London, Tokyo, or a houseboat in the Maldives, the IRS considers every satoshi you own as part of your taxable estate. Always. Forever. Unless you formally renounce — and even then, there's an exit tax.

Layer on a second citizenship — UK, Canadian, or any other country with its own inheritance tax regime — and you have two sovereign powers asserting the right to tax the same Bitcoin at death. The treaties designed to prevent double taxation were written in the 1970s and 1980s. They don't mention digital assets. They barely contemplate intangible property that exists simultaneously everywhere and nowhere.

This is the guide to understanding what you're actually up against — and what can be done about it. If you're looking for general Bitcoin estate planning fundamentals, start there first. This article assumes you already understand the basics and need to navigate the specific hell of dual citizenship.

The US Citizenship-Based Taxation Trap

Most countries tax based on residency. Live in France, pay French taxes. Move to Singapore, pay Singapore taxes. Straightforward. The United States does not work this way.

Under IRC §2001, every US citizen is subject to estate tax on their worldwide gross estate at death. It does not matter where you live, how long you've been away, or whether you've set foot in the country in decades. A US passport — or a green card held long enough — is a permanent tax relationship with the IRS that survives geography, time zones, and personal intention.

For Bitcoin holders, this creates a particularly vicious dynamic. Bitcoin's value has appreciated dramatically for early adopters, meaning estates that might have been comfortably below the exemption threshold a few years ago are now well above it. The 2026 federal estate tax exemption under the One Big Beautiful Bill Act sits at $15 million per person ($30 million for married couples using portability). Above that, the rate is 40%.

The annual gift tax exclusion for 2026 is $19,000 per recipient. Gifting Bitcoin during life can reduce estate exposure, but with significant complications for dual citizens — the receiving jurisdiction may treat the gift differently, and the cost basis implications vary dramatically between countries. Our international estate planning guide covers the broader framework.

US-UK Dual Citizens: Double 40% on the Same Bitcoin

The US-UK combination is among the most punishing for Bitcoin holders, because both countries impose estate-level taxes at 40% — and they calculate them differently.

How Each Country Taxes at Death

United States: Estate tax at 40% on worldwide assets above the $15 million exemption. Applies to all US citizens regardless of residence. Bitcoin is valued at fair market value on the date of death (or alternate valuation date, six months later).

United Kingdom: Inheritance Tax (IHT) at 40% on worldwide assets above the £325,000 nil-rate band (£500,000 with the residence nil-rate band, if applicable). Applies to individuals who are UK domiciled — a concept distinct from residency. If you were born in the UK, lived there as a child, and consider it your permanent home, HMRC will likely consider you UK domiciled even if you've lived abroad for years.

The collision point: a US-UK dual citizen who is UK domiciled faces both taxes on the same Bitcoin. The US imposes 40% on the worldwide estate. The UK imposes 40% on the worldwide estate. Same Bitcoin. Two 40% levies.

The Treaty Credit Mechanism

The US-UK Estate Tax Treaty (1978, amended by protocol in 1979) provides a credit mechanism to mitigate double taxation. But "mitigate" is the operative word — it does not eliminate it.

The treaty allows each country to provide a credit for taxes paid to the other, but the credit is limited. It's not dollar-for-dollar relief. The credit is calculated based on the proportion of estate attributable to each jurisdiction, and because the two countries have different exemption thresholds, different calculation methods, and different definitions of what constitutes the taxable estate, the credit rarely provides complete relief.

A simplified illustration: if a US-UK dual citizen dies with 80 BTC worth $8 million total, the UK IHT liability (after the nil-rate band) might be approximately £2.9 million (~$3.6 million). The US estate tax liability might be $0 if the estate falls below the $15 million exemption. In this case, the double-tax problem is manageable. But at 200 BTC worth $20 million, the US estate tax kicks in hard, and the credit mechanism provides only partial relief.

ISA/Pension vs. IRA Treatment

Another layer of complexity: UK ISAs (Individual Savings Accounts) and UK pensions receive favorable treatment under UK tax law but are not recognized as tax-advantaged by the IRS. Conversely, US IRAs may not receive treaty-protected treatment under UK law in all circumstances.

If you hold Bitcoin through a US-based IRA (such as a self-directed IRA with Bitcoin), the UK will generally respect the treaty provisions and not impose IHT on that IRA. But if you hold Bitcoin in a UK pension wrapper, the US may still include it in your worldwide estate for estate tax purposes, depending on the specific pension structure and whether it qualifies for treaty protection.

The practical effect: dual citizens cannot simply move assets between US and UK wrappers assuming equivalent treatment. Every wrapper must be analyzed under both systems.

US-Canada Dual Citizens: Estate Tax Meets Deemed Disposition

The US-Canada combination presents a different kind of problem — not double estate tax, but the collision of two fundamentally different tax-at-death mechanisms.

Canada's "No Estate Tax" Trap

Canada technically has no estate tax. This sounds favorable until you understand what replaces it. Under subsection 70(5) of the Income Tax Act, Canada imposes a deemed disposition at death — the deceased is treated as having sold all capital property at fair market value immediately before death. All unrealized capital gains become realized and taxable on the deceased's final (terminal) T1 return.

For Bitcoin holders, this is devastating. If you acquired Bitcoin at $1,000 and it's worth $100,000 at death, Canada taxes the $99,000 capital gain per coin on your terminal return. The top marginal rate on capital gains in Canada (with the 2024 changes increasing the inclusion rate to two-thirds for gains above $250,000) can exceed 35% in most provinces.

The double hit: The US imposes 40% estate tax on the value of the Bitcoin. Canada imposes ~35% capital gains tax on the deemed disposition of the same Bitcoin. These are different types of tax — estate tax versus income tax — and the treaty credit provisions don't fully bridge the gap.

Treaty Credit Limitations

The US-Canada Estate Tax Treaty (Convention) allows a credit for Canadian income tax arising from the deemed disposition against US estate tax liability. But the credit is limited to the amount of US estate tax attributable to the Canadian-situs property. And here's the critical problem for Bitcoin: the "situs" of Bitcoin under the treaty is ambiguous, because the treaty predates cryptocurrency by decades.

If Bitcoin is treated as property situated in Canada (because the owner resides there), the credit works reasonably well. If it's treated as property situated in the US (because the owner is a US citizen), the credit mechanism may not provide adequate relief on the Canadian side.

TFSA vs. Roth Complications

Canada's Tax-Free Savings Account (TFSA) is not recognized by the IRS as a tax-exempt vehicle. Any Bitcoin gains inside a TFSA are tax-free in Canada but fully taxable in the US. The reporting requirements alone are burdensome — a TFSA may be classified as a foreign trust under IRC §6048, triggering Forms 3520 and 3520-A, with penalties of $10,000 or more per missed form.

Conversely, a US Roth IRA receives some treaty protection in Canada, but the treatment is complex and the CRA has issued conflicting guidance over the years. The key issue: both the TFSA and Roth IRA were designed as domestic tax incentives, and neither country's treaty framework fully accommodates the other's wrapper.

Spousal Rollover vs. Marital Deduction

In Canada, the deemed disposition at death can be deferred if assets roll over to a surviving spouse or common-law partner (subsection 70(6)). This is an automatic rollover at the deceased's cost base — no tax until the surviving spouse dies or disposes of the property.

In the US, the unlimited marital deduction (IRC §2056) eliminates estate tax on assets passing to a surviving US citizen spouse. But if the surviving spouse is not a US citizen, the marital deduction is denied — assets must pass through a Qualified Domestic Trust (QDOT) to defer tax.

The conflict: a US-Canada dual citizen married to a Canadian (non-US citizen) spouse can get the Canadian spousal rollover but cannot get the US marital deduction without a QDOT. And a QDOT holding Bitcoin creates its own problems — the QDOT trustee must be a US citizen or domestic corporation, which may create Canadian tax complications. See our green card estate tax planning guide for more on the QDOT mechanics.

The Situs Problem: Where Does Bitcoin Live?

Traditional estate tax analysis depends on knowing where an asset is "situated" — its situs. Real estate is in the country where the land sits. Shares are typically situated where the company is incorporated. Cash is where the bank is. These rules are old, established, and generally predictable.

Bitcoin breaks all of them.

Bitcoin exists on a distributed ledger replicated across thousands of nodes worldwide. It has no physical location. It's not issued by any company. It's not held by any bank (unless you're using a custodian). Where, exactly, is it?

Three Countries, Three Answers

Country	Situs Rule for Bitcoin	Practical Effect
United States	Intangible personal property — situated where the owner is domiciled	For US citizens, Bitcoin is US-situs property regardless of where it's stored or administered
United Kingdom	Where the asset is administered or the custodian is located	Bitcoin on a UK exchange may be UK-situs; self-custodied Bitcoin situs is ambiguous
Canada	Where the owner resides (for most intangible property)	A Canadian-resident holder's Bitcoin is generally treated as Canadian-situs

The same 80 BTC can be simultaneously US-situs (because the owner is a US citizen), UK-situs (because it's held on a UK-based exchange), and Canadian-situs (because the owner resides in Canada). Three countries, three claims, one pile of Bitcoin.

Self-custody makes this worse, not better. When Bitcoin is on a hardware wallet in a safe deposit box in Zurich, controlled by a US-UK dual citizen living in London, where is it? The US says: with the owner's domicile (US). The UK says: where it's administered (arguably London, arguably Zurich). HMRC has not issued definitive guidance on self-custodied cryptocurrency situs, and neither has the IRS published formal situs rules specific to crypto.

This ambiguity is not academic. It determines which country gets to tax what — and whether treaty credits apply. Our expat estate planning guide covers additional situs considerations for US persons abroad.

Treaty Limitations: Pre-Internet Law, Post-Internet Assets

The United States has estate tax treaties with approximately 16 countries. Most were negotiated and ratified between 1950 and 1985. None specifically address cryptocurrency. None contemplate an asset class that is simultaneously intangible, borderless, self-custodied, pseudonymous, and operating on a decentralized network.

The US-UK Estate Tax Convention (1978) classifies property into categories: real property, business property, and "other property." Bitcoin presumably falls into "other property," but the treaty's provisions for "other property" were designed for things like bank accounts, bonds, and art collections — assets with clear physical or institutional situs.

The US-Canada treaty is somewhat more modern but still predates the internet. Its credit mechanism for income taxes paid at death (to address the deemed disposition) works reasonably well for traditional assets with clear situs — publicly traded stocks, real estate, business interests. For Bitcoin, the situs ambiguity infects the credit calculation itself.

The 16-Country Problem

Only ~16 countries have estate tax treaties with the US. If you're a dual citizen of the US and a country without a treaty — which includes most of the world — there is no treaty mechanism to prevent double taxation at all. You're relying entirely on each country's domestic foreign tax credit provisions, which are typically less generous and more uncertain than treaty-based credits.

Countries that do have US estate tax treaties include the UK, Canada, France, Germany, Japan, Australia, and several others. Countries that do not include: most of Latin America, most of Asia, most of Africa, and most of the Middle East. If you're a US-Brazilian dual citizen holding 200 BTC, your exposure to double taxation is essentially uncapped.

The PFIC Trap

This is the trap that most dual citizens don't see coming until it's too late.

A Passive Foreign Investment Company (PFIC) under IRC §1291 is a foreign corporation where 75% or more of income is passive, or 50% or more of assets produce passive income. The penalties for holding PFIC shares without making proper elections are among the most punitive in the tax code: interest charges on deferred tax, taxation of gains at the highest ordinary income rate regardless of holding period, and loss of long-term capital gains treatment.

How does this apply to Bitcoin? If a dual citizen holds Bitcoin through a non-US investment vehicle — a UK investment trust, a Canadian corporation, a foreign fund — that entity may be a PFIC for US tax purposes. Bitcoin held in a UK ISA wrapper through a fund structure could trigger PFIC treatment. Bitcoin held through a Canadian trust company's pooled fund could trigger PFIC treatment.

The PFIC rules don't just affect the income tax during life. They affect the estate, because the accumulated deferred tax liability and interest charges carry over to the estate and reduce the after-tax inheritance for heirs. And because PFIC reporting requires Form 8621 for each PFIC each year, the compliance burden alone is substantial.

Dual Reporting Obligations

Dual citizens don't just face double taxation. They face double (or triple) reporting — to each country's tax authority, with different forms, different deadlines, different definitions, and different penalties for non-compliance.

US Reporting Requirements

• Form 706 — United States Estate (and Generation-Skipping Transfer) Tax Return. Due 9 months after death (extensions available). Reports the entire worldwide estate.
• FBAR (FinCEN 114) — Report of Foreign Bank and Financial Accounts. Required if the aggregate value of foreign financial accounts exceeds $10,000 at any point during the year. Bitcoin on a foreign exchange counts. Due April 15 (auto-extended to October 15).
• FATCA Form 8938 — Statement of Specified Foreign Financial Assets. Required for US persons with foreign financial assets exceeding $50,000 ($200,000 for those living abroad). Filed with the annual tax return.
• Form 3520/3520-A — If Bitcoin is held in a foreign trust structure (including structures that may be inadvertently classified as trusts).

UK Reporting Requirements

• IHT400 — Inheritance Tax Account. Filed with HMRC when the estate exceeds the nil-rate band or when IHT is due. Includes worldwide assets for UK-domiciled individuals.
• SA900 — Trust and Estate Tax Return, if assets pass through a trust or there's income in the estate during administration.

Canadian Reporting Requirements

• T1 Terminal Return — The deceased's final income tax return, including all deemed disposition gains on Bitcoin and other capital property.
• T3 Trust Return — If a testamentary trust is established, ongoing T3 returns are required annually for the trust.
• T1135 — Foreign Income Verification Statement for foreign property exceeding CAD $100,000 in cost.

The compliance burden for a dual citizen's estate is extraordinary. The executor must file returns in two (or more) countries, coordinate the timing of credit claims, ensure consistency in asset valuations between jurisdictions, and navigate different filing deadlines. Professional fees for cross-border estate administration routinely exceed $100,000 — before any tax is paid.

Trust Planning for Dual Citizens

Trusts are the primary vehicle for estate tax planning in the US. Irrevocable trusts, grantor trusts, dynasty trusts, GRATs, SLATs, QPRTs — the alphabet soup of US trust planning is deep and well-established. The problem for dual citizens is that a trust perfectly optimized for US purposes may be catastrophically wrong for the other country.

US Grantor Trust: The Cross-Border Problem

A US grantor trust (where the grantor is treated as the owner for income tax purposes) is a cornerstone of US estate planning. The grantor pays income tax on trust earnings, which is not treated as a gift to the trust — allowing the trust assets to grow tax-free while reducing the grantor's taxable estate.

The UK does not recognize this structure the same way. HMRC may treat a US grantor trust as a "relevant property trust" subject to:

• An entry charge of up to 20% when assets are transferred in
• 10-year periodic charges of up to 6% of the trust value
• Exit charges when assets are distributed

A US irrevocable grantor trust holding 50 BTC — perfectly efficient from a US perspective — could trigger periodic IHT charges in the UK that the grantor never anticipated. The trust may have saved US estate tax while creating an ongoing UK IHT liability that compounds over time.

Canadian Trust Complications

Canada treats most trusts as separate taxpayers and applies a 21-year deemed disposition rule — every 21 years, a trust is deemed to have disposed of all capital property at fair market value. For a Bitcoin trust, this means a massive capital gains tax event every 21 years, regardless of whether any actual distribution occurs.

Additionally, Canada's "attribution rules" can attribute trust income and gains back to the settlor in certain circumstances, defeating the purpose of the trust from a Canadian tax perspective while the US continues to treat it as a valid separate entity.

What Works (Sometimes)

For US-UK dual citizens, a structure that can work is a combination of:

• A US-compliant irrevocable trust for assets above the estate tax exemption, with specific provisions drafted to minimize UK "relevant property" treatment
• Direct ownership below the exemption amount, relying on the $15 million per person exclusion
• Careful use of the US-UK treaty credit mechanism to reduce (not eliminate) double taxation on trust distributions

For US-Canada dual citizens:

• A US-compliant trust that accounts for Canada's 21-year deemed disposition rule in its terms
• Spousal rollover planning coordinated with QDOT requirements if the surviving spouse is not a US citizen
• Strategic use of the capital gains exemption and principal residence exemption (where applicable) to reduce the deemed disposition impact

In all cases, the trust documents must be drafted by counsel licensed in both jurisdictions. A US trust attorney who doesn't understand UK IHT or Canadian deemed disposition rules will create a structure that optimizes for one country while creating problems in the other.

Renunciation: The Nuclear Option

When the cross-border complexity becomes intractable, some dual citizens consider renouncing one citizenship. This is the nuclear option — irreversible, emotionally significant, and laden with its own tax consequences.

Renouncing US Citizenship

Under IRC §877A, individuals who renounce US citizenship (or long-term residency) may be classified as "covered expatriates" if they meet any of three tests:

1. Net worth test: Net worth exceeds $2 million on the date of expatriation
2. Tax liability test: Average annual net income tax liability for the five preceding years exceeds a threshold amount (~$201,000 for 2026)
3. Certification test: Cannot certify five years of US tax compliance

A covered expatriate faces a mark-to-market exit tax — all worldwide assets are treated as sold at fair market value on the day before expatriation. For a Bitcoin holder with significant unrealized gains, this means a massive immediate income tax bill.

Additionally, the "inheritance tax" provision of §2801 imposes a tax on US persons who receive gifts or bequests from covered expatriates — essentially penalizing your US-based heirs for your decision to renounce.

Our expatriation and exit tax guide covers the mechanics in detail.

Renouncing UK Citizenship

The UK does not impose an exit tax on citizenship renunciation. However, IHT exposure is tied to domicile, not citizenship. Under the former non-dom rules (substantially reformed from April 2025), an individual who was UK-domiciled could not simply shed IHT exposure by renouncing citizenship — domicile is a common law concept that considers intent, ties, and long-term plans, not just passport status.

Under the new residence-based IHT regime (effective April 2025), individuals who have been UK resident for 10 of the previous 20 tax years are subject to IHT on worldwide assets. This is a "tail" that persists for 3-10 years after leaving the UK, depending on the length of prior UK residence.

Renouncing Canadian Citizenship

Canada imposes a deemed disposition on emigration (the "departure tax"), which functions similarly to its deemed disposition at death. All capital property is treated as sold at fair market value when you cease to be a Canadian resident. For Bitcoin holders, this means capital gains tax on all unrealized appreciation at the time of departure — even if you're not selling anything.

The departure tax can be deferred for certain types of property by posting security with the CRA, but Bitcoin is generally not eligible for deferral as it's not real property or shares of a Canadian-controlled private corporation.

Case Study: The Campbell-Watsons

James Campbell-Watson, 54, and his wife Eleanor, 51, are US-UK dual citizens living in London. James was born in New York to a British mother and American father; Eleanor was born in Bristol and acquired US citizenship through naturalization after they lived in San Francisco for eight years early in their marriage. They returned to London in 2018.

The Profile

• Bitcoin holdings: 80 BTC, acquired between 2015-2019 at an average cost basis of approximately $4,200 per coin
• Current value: ~$8 million (at $100,000/BTC)
• Other assets: London flat worth £1.8 million, UK pension valued at £420,000, US 401(k) from prior employment worth $310,000, cash and equities of approximately £600,000
• Total estimated estate: ~$12 million
• Children: Two, ages 19 and 22, both dual citizens, one at university in the US and one in London
• Future plans: Considering returning to the US within 5-7 years to be closer to aging parents

The Problem

James and Eleanor's estate currently falls below the US $15 million per person exemption, so US estate tax is not an immediate concern. But UK IHT is a different story — the £325,000 nil-rate band means almost their entire estate is subject to 40% IHT.

The real risk is forward-looking. If Bitcoin appreciates to $200,000 — not an unreasonable scenario given the asset's trajectory — their 80 BTC alone would be worth $16 million, pushing the total estate above the US exemption threshold. Now both countries want 40% of the same Bitcoin.

If James dies while UK-domiciled, the UK claims IHT on his entire worldwide estate. The US claims estate tax on his entire worldwide estate as a US citizen. The treaty credit mechanism provides partial relief, but the net effective rate could exceed 55% on the Bitcoin.

The Planning Response

Their cross-border estate planning team (a US tax attorney, a UK solicitor specializing in IHT, and a cross-border tax accountant) developed a multi-layer approach:

1. Lifetime Gifting Program

James and Eleanor each gift $19,000 of Bitcoin annually to each child — $76,000 per year total — using the US annual gift tax exclusion. Over 10 years, this removes approximately $760,000 from the estate with no gift tax and no use of the lifetime exemption. The gifts are structured to also comply with UK "potentially exempt transfer" (PET) rules: if the donor survives seven years after a PET, it falls out of the IHT estate entirely.

2. US Irrevocable Life Insurance Trust (ILIT)

An ILIT owns a survivorship life insurance policy on both lives. The death benefit (outside both estates) provides liquidity to pay any estate tax without forcing the sale of Bitcoin. The ILIT is structured to be a US-situs trust, with UK counsel confirming its treatment under IHT.

3. Bitcoin Segmentation by Jurisdiction

The 80 BTC is divided across custody structures that optimize situs treatment:

• 30 BTC held in a US-based qualified custodian (clear US situs, covered by US exemption)
• 30 BTC in self-custody on hardware wallets administered from London (UK situs, subject to IHT but eligible for treaty credit against any US estate tax)
• 20 BTC gradually transferred through the gifting program over the coming years

4. UK Will / US Will Coordination

Separate wills for US and UK assets, drafted by attorneys in each jurisdiction but coordinated to avoid conflicting provisions. The US will references the UK will and vice versa — ensuring neither inadvertently revokes the other. This is a common failure point in dual-citizen planning: a new US will with a standard "I revoke all prior wills" clause can invalidate a carefully drafted UK will.

5. Return-to-US Contingency

If James and Eleanor return to the US, their UK domicile status may change over time, reducing IHT exposure on worldwide assets (subject to the new residence-based tail period). The plan includes a review trigger at the point of relocation to restructure the custody segmentation and trust arrangements for the new residence jurisdiction.

The Action Plan

If you are a dual citizen holding significant Bitcoin, the following steps are not optional — they are the minimum required to prevent your heirs from losing the majority of your holdings to double taxation.

1. Engage cross-border counsel in both jurisdictions. A US tax attorney alone is not sufficient. A UK solicitor alone is not sufficient. You need both, and they need to be communicating with each other. The same applies to US-Canada: a Canadian tax lawyer and a US tax attorney, working together.

2. Map the situs of every Bitcoin holding. Where is each tranche of Bitcoin custodied? Which country claims situs? Does the custody arrangement optimize or worsen your treaty credit position? Self-custodied Bitcoin needs explicit situs analysis — don't assume it's favorable.

3. Coordinate wills across jurisdictions. Separate wills for each jurisdiction, drafted by local counsel, reviewed by counsel in the other jurisdiction, and explicitly coordinated to avoid revocation conflicts.

4. Model the double-tax exposure. Run the numbers under both countries' systems at current values and at 2x, 5x, and 10x Bitcoin price scenarios. The exemption that protects you today may not protect you tomorrow. Bitcoin's volatility makes static planning dangerous.

5. Evaluate trust structures under both tax regimes. Any trust used for estate planning must be analyzed under both countries' laws. A structure that saves tax in one country but creates liability in the other is not a solution — it's a different problem.

6. Comply with all reporting obligations in both countries. The penalties for non-compliance with FBAR, FATCA, Form 3520, IHT400, and T1135 are severe and can compound the financial damage of double taxation. Full compliance is not optional; it's the foundation on which all planning rests.

7. Revisit the plan annually. Tax laws change. Treaty interpretations evolve. Bitcoin's value fluctuates dramatically. Estate tax exemptions can sunset or be extended. A plan built for 2026 may be wrong for 2027. Annual review with cross-border counsel is the cost of holding Bitcoin across two jurisdictions.

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Dual citizenship is a privilege in most dimensions of life. In estate planning for Bitcoin holders, it is a structural liability — one that requires more planning, more coordination, more professional fees, and more vigilance than single-citizenship holders will ever face. The treaties are old. The guidance is sparse. The stakes, at 40% per country, are existential for generational wealth.

The good news: with proper planning, the double-tax exposure can be significantly reduced — not to zero, but to a managed cost rather than a catastrophic one. The prerequisite is taking action before death forces the issue, because cross-border estate administration without pre-planning is the most expensive legal process most families will ever encounter.

Start with the comprehensive estate planning guide if you haven't already. Then add the cross-border layer with qualified counsel in both jurisdictions. The clock isn't necessarily running — but Bitcoin's price might be, and every dollar of appreciation without a plan in place is a dollar at risk of double taxation.