General answers by Juristbyrå Simon Dicksved
Swedish inheritance-law practice · Available in English and Swedish

Editorially prepared: June 30, 2026

Editorial format notice: These questions are written to reflect how clients naturally ask about cross-border estates. The answers present the firm’s general educational explanation; they are not a verbatim interview, individualized legal advice, or a statement of U.S. law. No result, timeline, or outcome is promised. Swedish legal claims require Simon’s final approval before publication, and U.S. issues require review by appropriately licensed U.S. counsel.

The first conversation about an international estate usually begins with a practical question rather than a legal term. Below, the client’s question is followed by the issues Simon would normally want a family to understand before anyone chooses a legal or administrative step. Every estate depends on its documents, dates, family relationships, assets, and jurisdictions. Use this guide to organize the right questions—not to decide your rights or calculate a deadline.

What is the biggest difference?

The largest difference is structural. In the United States, probate is governed primarily by the law and court procedure of a particular state. A court may appoint a personal representative and issue documents proving authority. In Sweden, estate parties commonly administer the estate jointly without routine court supervision. They prepare an estate inventory that is registered with the Swedish Tax Agency, manage the property, address liabilities, and later enter an estate distribution agreement. Swedish courts become involved when a statute requires it or someone requests measures such as appointment of an official estate administrator or estate distribution executor. Calling both systems “probate” can be convenient in conversation, but it hides important distinctions. I prefer to create two columns—Swedish tasks and U.S. tasks—and connect them only where a document, asset, deadline, or decision genuinely depends on the other side.

Who represents the estate in each system?

A U.S. probate court may appoint an executor named in a will or another personal representative, depending on state law. That person’s authority is evidenced by the court’s documents and limited by the governing law and orders. In Sweden, the estate parties generally represent the estate jointly once their status can be established, often through the registered estate inventory. A will can name a testamentary executor, and a district court can appoint a boutredningsman who takes over administration. These roles are not interchangeable merely because an English translation uses “executor” or “administrator.” Before a Swedish bank or buyer acts, it wants to know who has authority for the particular transaction. Before a U.S. lawyer relies on a Swedish document, that lawyer needs to understand the document’s legal function. Role mapping prevents unauthorized signatures and contradictory instructions.

Are the court and tax authority doing the same job?

No. The Swedish Tax Agency registers estate inventories and performs functions assigned to it by Swedish law, but it is not a probate court deciding every disagreement among heirs. A Swedish district court can appoint an estate administrator or distribution executor and hear certain inheritance disputes. In a U.S. state, a probate court can supervise or adjudicate matters under that state’s procedure. The fact that a Swedish document bears an agency registration stamp does not make it a judgment on every issue. Likewise, an American probate order may establish authority in that state without completing Swedish registration or transfer requirements. Ask three questions about any official document: who issued it, what issue that authority decided, and where the document is intended to operate. Those questions are more useful than debating which country’s document is “stronger.”

Why might two proceedings be necessary?

Two workstreams may be necessary because assets and institutions sit in different legal systems, and because the deceased’s residence, citizenship, planning documents, and property create connecting factors that no single clerk or bank can ignore. A U.S. court may need to appoint a representative for local accounts or property while Swedish parties prepare the inventory and handle Swedish assets. The applicable succession law is a separate analysis from the procedural steps needed to control an asset. Even if one country’s law governs succession broadly, local formalities may still govern registration, sale, or access. A coordinated matter does not mean every task must wait for every other task. The chronology should identify which steps can proceed in parallel, which foreign document must be obtained first, and who will provide certified copies, translations, and explanations.

Can one lawyer manage everything?

One person can coordinate, but no professional should imply authority they do not have. Simon Dicksved is presented here as a Swedish jurist, not as a lawyer admitted in any U.S. state. He may scope and perform agreed Swedish-law work. A U.S. probate filing, state-law opinion, or appearance in court requires appropriately licensed U.S. counsel. Tax reporting may require a qualified tax adviser. Good coordination assigns a lead contact without blurring professional responsibility. The engagement letters should say who advises on Swedish succession and administration, who handles the American proceeding, who addresses tax, and who makes decisions for the client or estate. Shared timelines and document indexes are useful; shared assumptions are dangerous. If an adviser uses a foreign-law conclusion, ask whether it has been confirmed by someone qualified in that jurisdiction.

What documents usually travel between the systems?

Common cross-border documents include death certificates, family or civil-status records, wills and codicils, court appointments, letters of authority, the Swedish estate inventory, distribution agreements, powers of attorney, deeds, account statements, and identity evidence. A document may need certification, notarization, apostille, or translation, but the requirement depends on the recipient and purpose. More authentication is not always better; it can add expense without curing a substantive gap. Build a document matrix listing the original issuer, date, current holder, required format, language, destination, and what the recipient expects it to prove. Do not send original wills or irreplaceable civil records casually. Use tracked delivery where originals are required and retain complete copies. Secure transmission is particularly important when documents include personal identity numbers, account details, or signatures.

How should the family communicate across both matters?

Choose one factual chronology and one asset list, then allow each adviser to add jurisdiction-specific fields. Identify the deceased consistently and record name variations. Use defined terms for every role: “Swedish estate party,” “U.S. personal representative,” and “attorney-in-fact” are clearer than calling everyone the executor. Hold short decision-focused meetings rather than forwarding long email chains without context. Each material decision should record who had authority, what advice was received, what assumptions remain, and what deadline follows. If family members disagree, avoid using the foreign process as leverage—for example, withholding a Swedish signature to force a U.S. concession—without understanding the legal consequences. Clear communication does not eliminate conflict, but it helps advisers distinguish a legal dispute from an information problem.

What is a sensible first plan?

First, identify every jurisdiction connected to the deceased and each significant asset. Second, determine whether anyone has already been formally appointed or has taken control of property. Third, secure property and preserve records without distributing assets. Fourth, collect the will, civil-status evidence, and initial financial information. Fifth, obtain Swedish and relevant U.S. advice on the proposed division of work. Sixth, create deadlines and dependencies, including the Swedish inventory timetable and any U.S. court dates or creditor periods identified by local counsel. Seventh, agree how costs and translations will be authorized. This plan is deliberately practical. The governing-law analysis can be sophisticated, but a surprising number of delays begin with missing statements, unclear names, inaccessible mail, or two advisers waiting for each other to make the first request.

Simon, what should I do next?

Book the free 30-minute first call. You do not need to collect or send documents before speaking with Simon; simply explain where Sweden enters the matter and whether Swedish bank assets, property or a cooperative apartment, or both are involved. Simon can then review fit, scope, and conflicts. If the matter proceeds, he sends an engagement agreement for signature before requesting the relevant documents. Contacting the firm does not create a lawyer-client or attorney-client relationship, stop a deadline, or guarantee representation. If a court, authority, bank, or other adviser has given you a date, obtain matter-specific advice promptly.

Primary sources and further reading

Sources are provided for general orientation and may change. Access current official guidance and obtain professional review before acting.