ITCMD Brazil 2026 — Inheritance Tax Guide for Foreigners

ITCMD (Imposto sobre Transmissao Causa Mortis e Doacao) is Brazil’s inheritance and gift tax, levied by individual states on the transfer of assets at death and on lifetime donations. Rates range from 2% to 8%, with most states moving to progressive structures following LC 227/2026. Unlike the US federal estate tax with its $13.61 million exemption, ITCMD applies from the first real of transferred value in most states — meaning virtually every inheritance in Brazil triggers a tax obligation. For foreigners with Brazilian assets, ITCMD is the single largest cost of succession after the assets themselves.

What Is ITCMD?

ITCMD is a state-level tax authorized by CF Art. 155, II of the Federal Constitution. Each of Brazil’s 26 states and the Federal District sets its own rates, exemptions, and procedures — subject to the federal ceiling of 8% established by Resolucao do Senado 9/1992. The tax applies to two events:

1. Causa mortis (inheritance): When assets pass from a deceased person to their heirs, whether by will or intestate succession
2. Doacao (donation): When assets are transferred as a gift during the donor’s lifetime

The taxpayer is the heir (for inheritances) or the donee (for gifts). The tax is calculated on the market value of the assets transferred, and payment is due before assets can be transferred in the probate process.

What Are the Current ITCMD Rates by State?

The following table shows current ITCMD rates and projected post-reform rates for major states. Under EC 132/2023 and LC 227/2026, all states must adopt progressive rates — meaning flat-rate states will transition to tiered structures.

State	Current Rate	Rate Structure	Projected Post-Reform Rate	Implementation Status
Sao Paulo (SP)	4% (flat)	Flat	2%-8% (progressive)	Legislation pending; expected 2027
Rio de Janeiro (RJ)	4%-8%	Progressive (4 brackets)	4%-8% (adjusted brackets)	Already progressive; minor adjustments expected
Minas Gerais (MG)	5% (flat)	Flat	2%-8% (progressive)	Legislation pending
Santa Catarina (SC)	1%-8%	Progressive (7 brackets)	1%-8% (adjusted brackets)	Already progressive
Rio Grande do Sul (RS)	3%-6%	Progressive (3 brackets)	3%-8% (progressive)	Legislation under review
Bahia (BA)	4%-8%	Progressive (3 brackets)	4%-8% (adjusted brackets)	Already progressive
Parana (PR)	4% (flat)	Flat	2%-8% (progressive)	Legislation pending
Distrito Federal (DF)	4%-6%	Progressive (2 brackets)	4%-8% (progressive)	Legislation under review

“For Americans in Brazil, ITCMD is the single largest succession cost after the assets themselves. Unlike the US estate tax with its $13.61 million exemption, ITCMD hits from the first real — and with progressive rates coming, high-value estates face an effective doubling of their tax bill.” — Zachariah Zagol, Founding Partner, OAB/SP 351.356

Key takeaway: Sao Paulo — where most foreign-owned Brazilian assets are concentrated — currently charges a flat 4%. The move to progressive rates of up to 8% effectively doubles the ITCMD on high-value estates. For an estate worth R$10 million in SP, the tax could increase from R$400,000 to R$800,000.

How Is ITCMD Calculated?

Tax Base

ITCMD is calculated on the market value (valor venal) of the assets transferred. Post-LC 227/2026 Art. 154, “market value” is strictly interpreted as the price the asset would fetch in an arm’s-length transaction — not the assessed value for IPTU purposes, which is typically 30-60% below market value.

For different asset types, the tax base is determined as follows:

• Real estate: Appraised market value at the date of death or donation. States may use their own reference values (valor de referencia), which heirs can challenge if above market.
• Financial assets: Balance or market value at the date of death. Includes bank accounts, CDBs, stocks, investment funds, and PGBL/VGBL pension plans.
• Business interests: Book value or appraised value of the quota/share, depending on the state. For holding companies, this includes the value of underlying real estate held by the entity.
• Vehicles: FIPE table value at date of death.
• Foreign assets: Under LC 227/2026, ITCMD now applies to assets located abroad received by a Brazilian-domiciled heir. This resolves the prior legal vacuum identified in STF RE 851.108.

Exemptions

Each state establishes its own exemptions. Common exemptions include:

• Low-value estates: Many states exempt inheritances below a threshold (e.g., SP exempts estates up to 2,500 UFESPs — approximately R$82,000 in 2026).
• Small donations: Annual donation exemptions vary. SP exempts individual donations up to 2,500 UFESPs per donee per year.
• Principal residence: Some states (e.g., RJ) offer reduced rates or exemptions for the deceased’s primary residence when inherited by the surviving spouse or dependents.
• Agricultural property: Limited exemptions exist in some states for small rural properties inherited by family farmers.
• VGBL pension plans: VGBL plans are generally not subject to ITCMD because they are classified as insurance products, not estate assets. However, PGBL plans are subject to ITCMD. This distinction is actively litigated — some states attempt to tax both.

Deductions

The following can typically be deducted from the tax base:

• Debts of the deceased proven by documentation
• Funeral expenses (up to a state-set limit)
• Court costs and attorney fees for the inventory proceeding (in some states)
• Outstanding mortgage balance on inherited real estate

How Does ITCMD Apply to Donations vs. Inheritances?

ITCMD applies to both, but with important differences that create planning opportunities:

Inheritance (causa mortis):

• Taxed at the time of the inventory
• Tax base is the estate value at date of death (or partition, depending on state)
• 60-day filing deadline; penalties for late payment
• Cannot be planned retroactively

Donation (inter vivos):

• Taxed at the time of the gift
• Tax base is the asset value at the time of donation
• No filing deadline — but must be declared in the annual tax return
• Can be strategically timed to minimize tax impact

The planning implication is significant: donating assets during your lifetime at current flat rates — before your state implements progressive rates under LC 227/2026 — can reduce the effective ITCMD burden by 50% or more. A R$5 million donation in Sao Paulo today pays 4% ITCMD (R$200,000). The same transfer as an inheritance after progressive rates are implemented could pay 8% (R$400,000).

Does ITCMD Apply to Foreign Assets?

This question was unresolved for years. The STF in RE 851.108 held in 2021 that states could not charge ITCMD on foreign inheritances and donations without a complementary federal law authorizing it. This created a window where inheritances received from abroad were effectively ITCMD-free.

LC 227/2026 closed this window. The law provides the complementary legislation the STF required. Under the new framework:

• Inheritance from a foreign decedent, assets located abroad: ITCMD is owed to the state where the Brazilian heir is domiciled (LC 227/2026 Art. 152)
• Donation from a foreign donor, assets located abroad: ITCMD is owed to the state where the Brazilian donee is domiciled
• Assets located in Brazil, foreign heir: ITCMD is owed to the state where the asset is located (this was always the rule and remains unchanged)

For American expats in Brazil: If you inherit assets from a US relative — stocks, real estate, bank accounts located in the US — you now owe ITCMD to your Brazilian state of domicile. This is a dramatic change from the pre-2026 regime and requires immediate attention in your estate planning.

How Does the New ITCMD Reform Affect Foreigners?

The combination of EC 132/2023 and LC 227/2026 fundamentally changes the ITCMD landscape for foreigners in Brazil:

1. Progressive rates are mandatory. States can no longer maintain flat rates. High-value estates will pay more than before — potentially double in states like SP and PR that currently charge flat 4%.

2. Market value is now the standard. The practice of using assessed (IPTU) values to calculate ITCMD — which effectively reduced the tax base by 40-60% — is ending. Art. 154 mandates market value, which state tax authorities will enforce through their own valuation databases.

3. Foreign assets are now taxable. Brazilian residents receiving inheritances or gifts from abroad now owe ITCMD. This affects every American in Brazil who expects to inherit from family in the US.

4. Trust provisions create new exposure. Arts. 146-151 of LC 227/2026 define how ITCMD applies to trusts and trust-like structures. Assets held in foreign trusts for the benefit of Brazilian residents may trigger ITCMD at the time of distribution — or even at the time of trust creation.

5. Donation aggregation rules tighten. Arts. 155-157 aggregate donations made over a 5-year rolling window, preventing the strategy of breaking large gifts into small annual amounts to stay below progressive rate thresholds.

How Does ITCMD Apply to Different Asset Types?

Different asset types receive different ITCMD treatment. Understanding these distinctions is critical for planning.

Real Estate

ITCMD on real estate is owed to the state where the property is located — regardless of where the deceased lived or where the heirs reside. For a foreigner who owns properties in multiple Brazilian states, each state collects its own ITCMD on the property within its borders. The tax base is market value under LC 227/2026 Art. 154, and state tax authorities (SEFAZ) are increasingly using automated valuation databases to challenge low declared values.

Practical issue for foreigners: If the property registry (matricula) shows a purchase price of R$500,000 from 2015, but the current market value is R$1,200,000, ITCMD is calculated on R$1,200,000. The SEFAZ may accept a formal appraisal that shows a value lower than their database suggests, but the appraisal must be from a qualified perito avaliador and will be scrutinized.

Financial Investments and Bank Accounts

Bank account balances and investment portfolio values at the date of death are included in the ITCMD base. This includes CDBs, LCIs, LCAs, debentures, stock portfolios, and investment fund quotas. The financial institution freezes the account upon learning of the death and will only release funds upon presentation of the completed inventory document and proof of ITCMD payment.

For foreigners with Brazilian investment accounts: Banks require the foreign heir to have a CPF and present a power of attorney before they will provide the balance statement needed for the ITCMD calculation. This creates a circular dependency that must be carefully managed through the probate process.

Business Interests (Quotas and Shares)

Quotas in an LTDA or shares in an S.A. are subject to ITCMD at their fair market value. For publicly traded shares, this is the closing price on the date of death. For private companies, valuation is contentious — the company’s patrimonio liquido (book value/net equity) is the starting point, but if the company holds real estate or other appreciated assets, the SEFAZ may demand an appraisal of the underlying assets.

Holding companies face particular scrutiny under LC 227/2026’s look-through provisions. A holding company whose primary assets are real estate will see its quotas valued at the market value of the real estate — not the (typically lower) book value.

Vehicles

Vehicles are valued at the FIPE table reference price at the date of death. This is one of the few asset types where the valuation is straightforward and uncontested. ITCMD on vehicles is typically minimal compared to real estate and financial assets.

Intellectual Property and Royalty Streams

Less commonly addressed, but relevant for some foreign clients: intellectual property rights, patent royalties, and copyright income streams are subject to ITCMD. Valuation is based on the present value of expected future income — a complex calculation that typically requires an independent appraisal. For foreigners who hold Brazilian publishing rights, software licenses, or mineral royalties, this can represent a significant and unexpected ITCMD exposure.

How Do You Pay ITCMD?

Process

1. File the ITCMD declaration with the state tax authority (SEFAZ). In SP, this is done online via the DARE-ITCMD system.
2. Calculate the tax based on the state’s rate schedule applied to the market value of the transferred assets.
3. Generate the payment slip (DARE or guia de recolhimento) from the SEFAZ portal.
4. Pay at an authorized bank or via internet banking. Some states accept credit card or installment payments.
5. Obtain the clearance certificate (certidao de regularidade) confirming payment. This document is required before the notary or judge will authorize asset transfers.

Deadlines

• Causa mortis: ITCMD is due within 180 days of death in most states. Late payment triggers penalties of 10-20% plus interest (SELIC rate).
• Donations: ITCMD is due within 30 days of the donation in most states, or at the time of the annual tax filing.
• SP specific: Sao Paulo allows a 30-day grace period from the end of the inventory for payment, but penalties accrue from the date of death for late-filed inventories.

What Are the Best ITCMD Planning Strategies?

Strategy 1: Lifetime Donations at Current Rates

The most time-sensitive strategy. States with flat rates (SP, MG, PR) have not yet implemented progressive rates required by LC 227/2026. Donating assets now locks in the lower flat rate. In SP, donating R$10 million today costs R$400,000 in ITCMD (4%). After progressive rates take effect, the same transfer at death could cost R$800,000 (8%).

Critical nuance: Donations made within the 5 years prior to death may be aggregated with the estate for ITCMD purposes under the new donation aggregation rules. The strategy works best for donors with a longer life expectancy.

Strategy 2: Holding Company Restructuring

Transferring real estate into a holding company converts real property (subject to ITCMD at market value) into corporate quotas (subject to ITCMD at book value in many states). The difference can be substantial — a R$5 million apartment held directly has an ITCMD base of R$5 million, while the same apartment held through a holding company may have an ITCMD base equal to the company’s book value, which could be significantly lower depending on accounting treatment.

Post-reform note: LC 227/2026 Art. 154 targets this arbitrage by requiring “market value” for all assets. States are developing anti-avoidance rules, but implementation timelines vary. Holding structures established before enforcement begins retain their advantage until challenged.

Strategy 3: Life Insurance (VGBL)

VGBL pension/insurance plans are not considered part of the estate under prevailing judicial interpretation and are therefore not subject to ITCMD in most states. The STJ has consistently held that VGBL has an insurance character (the beneficiary is named, not the estate). Allocating a portion of your portfolio to VGBL transfers wealth outside the ITCMD base.

Caveat: Some states (notably RJ) have attempted to tax VGBL on inheritance. The constitutionality of this is under challenge. LC 227/2026 does not expressly address VGBL, leaving this a state-by-state analysis.

Strategy 4: Marriage Regime Planning

Your marriage regime determines how much of your assets are “estate” vs. “community property.” Under comunhao parcial de bens (partial community property), the surviving spouse’s meacao (50% of community assets) is NOT subject to ITCMD because it was always theirs — only the deceased’s 50% is taxed. Strategic regime selection can effectively halve the ITCMD base for married couples.

Strategy 5: Timing and Jurisdiction

ITCMD is a state tax. If you are relocating within Brazil — for example, from Rio de Janeiro (up to 8%) to Sao Paulo (currently 4%) — the timing of your move affects which state collects ITCMD on your estate. For donations, the tax is owed to the state where the donor is domiciled. For inheritances, it’s the state where the estate inventory is processed (generally the last domicile of the deceased).

How Is ITCMD Calculated? Worked Examples

Understanding ITCMD in the abstract is different from calculating it for a real estate. The following examples illustrate how ITCMD applies in common scenarios for foreigners.

Example 1: American Expat Dies in Sao Paulo (Current Flat Rate)

Facts: James, a US citizen, dies domiciled in SP. Assets: apartment worth R$2,000,000 (community property with spouse), investment portfolio R$1,500,000 (separate property), car R$150,000. Married under comunhao parcial de bens. Two adult children.

Calculation:

• Spouse’s meacao (not taxed): R$1,000,000 (50% of apartment, community property)
• Taxable estate: R$1,000,000 (James’s half of apartment) + R$1,500,000 (separate property) + R$150,000 (car) = R$2,650,000
• SP ITCMD at 4% flat: R$106,000
• Each heir’s ITCMD liability is proportional to their share

Example 2: Same Scenario Under Post-Reform Progressive Rates

Using the projected SP progressive brackets:

• R$353,600 at 0% (exempt) = R$0
• R$353,600 to R$1,060,800 at 2% = R$14,144
• R$1,060,800 to R$2,650,000 at 4% = R$63,568
• Total ITCMD: approximately R$77,712

In this mid-range estate, progressive rates actually produce a lower tax than the current flat 4% — because the lower brackets reduce the effective rate. The progressive system hurts high-value estates (above ~R$10M) and helps mid-range estates.

Example 3: High-Value Estate in Rio de Janeiro

Facts: Maria, a Portuguese citizen, dies domiciled in RJ. Assets: two apartments worth R$8,000,000, financial investments R$5,000,000, holding company quotas worth R$7,000,000. No spouse. Three children.

Calculation (current RJ progressive rates):

• Total taxable estate: R$20,000,000
• RJ rates: 4% on first R$400K, 4.5% on next R$600K, 5% on next R$1M, 6% up to R$5M, 7% up to R$10M, 8% above R$10M
• Approximate ITCMD: R$1,380,000

Example 4: ITCMD on a Lifetime Donation in Sao Paulo

Facts: Robert, an American living in SP, donates an apartment worth R$3,000,000 to his daughter.

• Current flat rate: R$3,000,000 x 4% = R$120,000
• Post-reform progressive rate: approximately R$140,000 (higher brackets apply to the top portion)
• Savings from donating now: approximately R$20,000 in this scenario — but for a R$10M+ donation, the savings could exceed R$200,000

What ITCMD Exemptions and Reductions Exist by State?

Each state sets its own exemptions. Here are the most relevant for foreigners:

Sao Paulo

• Estates valued below 2,500 UFESPs (~R$82,000): fully exempt
• Donations below 2,500 UFESPs per donee per calendar year: fully exempt
• No reduced rate for family home or agricultural property
• Legal basis: Lei Estadual 10.705/2000, Art. 6

Rio de Janeiro

• Primary residence inherited by surviving spouse or dependents: 50% reduction in ITCMD base (if the property is the only residential asset)
• Estates below R$100,000: exempt
• Donations below R$72,940 (15,000 UFIRs-RJ) per year: exempt
• Legal basis: Lei Estadual 7.174/2015

Minas Gerais

• Estates below 20,000 UFEMGs (~R$96,000): exempt
• Donations below 10,000 UFEMGs per year: exempt
• 50% reduction for rural properties inherited by family members who work the land
• Legal basis: Lei Estadual 14.941/2003

Santa Catarina

• Most generous exemption: estates below R$50,000 for real estate and R$20,000 for other assets
• Progressive rates start at 1% — the lowest effective rate in Brazil
• Legal basis: Lei Estadual 13.136/2004

Parana

• Estates below 1,000 UPF/PR (~R$137,000): exempt
• Very limited donation exemptions
• Legal basis: Lei Estadual 18.573/2015

Strategic note: Exemptions are applied per heir, not per estate, in some states. An estate worth R$400,000 divided equally among 5 heirs may fall below the per-heir exemption threshold in states like MG — resulting in zero ITCMD despite a substantial total estate.

How Does ITCMD Compare Internationally?

Feature	Brazil (ITCMD)	USA (Federal Estate Tax)	UK (Inheritance Tax)	France (Droits de Succession)	Japan (Inheritance Tax)
Tax type	State-level	Federal	National	National	National
Rate range	2%-8%	18%-40%	40% (flat)	5%-45%	10%-55%
Exemption threshold	Minimal (varies by state; ~R$82K in SP)	$13.61M (citizens); $60K (non-resident aliens)	GBP 325,000	EUR 100,000 (children)	JPY 30M + JPY 6M/heir
Who pays	Heir/donee	Estate	Estate	Heir	Heir
Applies to worldwide assets?	Yes, for domiciled residents (post-LC 227/2026)	Yes, for citizens/domiciliaries	Yes, for domiciled individuals	Yes, for domiciled individuals	Yes, for residents
Tax treaty with Brazil?	N/A	No	No	No	No

The critical takeaway: Brazil has no estate/inheritance tax treaty with any major country. This means double taxation is the default outcome for cross-border estates. The only relief available is unilateral foreign tax credits — and these are complex to claim. See our Brazil vs. USA estate tax comparison for detailed analysis.

What Are Common ITCMD Mistakes Foreigners Make?

“The window between LC 227/2026’s enactment and state-level implementation is the last planning opportunity for certain strategies. Donations at flat rates, holding company transfers at book value — these tools have an expiration date.” — Zachariah Zagol, Founding Partner, OAB/SP 351.356

Mistake 1: Using IPTU value for the ITCMD declaration. Many Brazilians historically declared real estate at the IPTU assessed value — often 30-60% below market. State tax authorities now cross-reference declared values with their own databases and real estate transaction records. Declaring a low value triggers a tax assessment challenge (impugnacao), penalties, and delays. Post-LC 227/2026, this practice is explicitly prohibited.

Mistake 2: Ignoring the 60-day filing deadline. The inventory must be filed within 60 days of death (CPC Art. 611). Foreign families frequently miss this deadline while gathering apostilled documents and consular POAs. The penalty is automatic: 10% surcharge on ITCMD in most states, increasing to 20% after 180 days in states like Sao Paulo. File the inventory on time even if documents are incomplete — they can be supplemented later.

Mistake 3: Failing to declare foreign inheritances. Before LC 227/2026, foreign inheritances were ITCMD-free. Many expats assume this is still the case. It is not. If you received an inheritance from abroad after LC 227/2026 took effect and your state has implemented the new provisions, you owe ITCMD. Failure to declare triggers the same penalties as failure to pay, plus potential fraud liability.

Mistake 4: Assuming VGBL is automatically exempt. While prevailing jurisprudence treats VGBL as insurance (exempt from ITCMD), some states are aggressively challenging this classification — particularly for VGBL plans with large balances or plans where contributions were made close to death. The exemption is defensible but not automatic; it requires proper documentation and may require judicial defense.

Mistake 5: Not coordinating Brazilian and US tax filings. ITCMD paid to Brazil may be creditable against US estate tax under IRC Section 2014. But claiming the credit requires the US estate attorney to have the Brazilian ITCMD payment documentation (DARE receipts, SEFAZ clearance certificates) — documents that the Brazilian attorney must provide in the correct format. Without coordination, the credit is lost.

Frequently Asked Questions

What is the ITCMD rate in Sao Paulo?

Sao Paulo currently charges a flat 4% on both inheritances and donations. This rate has been in effect since 2000 under Lei Estadual 10.705/2000. However, following the progressive rate mandate in EC 132/2023 and LC 227/2026, SP must adopt a tiered structure of 2%-8%. The implementing legislation is expected in late 2026 or early 2027, with the progressive rates taking effect no earlier than January 2027.

Do I have to pay ITCMD if the deceased lived abroad?

For assets located in Brazil — yes, regardless of where the deceased lived. ITCMD is owed to the state where the asset is located (for real estate) or where the inventory is processed. For assets located abroad inherited by a Brazilian resident, ITCMD is now also owed under LC 227/2026.

Is ITCMD tax-deductible in the US?

ITCMD paid on an inheritance is not deductible on your US income tax return (Form 1040). However, if you are the executor of a US estate that also owes US estate tax, ITCMD paid to Brazil may qualify as a foreign tax credit on Form 706 under IRC Section 2014. This credit is available only for estates of US citizens and residents and requires careful documentation.

Can I pay ITCMD in installments?

Some states allow installment payment (parcelamento). Sao Paulo permits up to 12 monthly installments for ITCMD on causa mortis, subject to interest at the SELIC rate. Not all states offer this option, and the installment plan must be approved before the inventory is finalized. For donations, installment payment is generally not available.

How is ITCMD calculated on jointly held property?

Joint ownership (condominio) means each co-owner holds a defined percentage. ITCMD is calculated only on the deceased’s share. If you and your spouse own property 50/50 and you die, ITCMD applies to your 50%. The surviving spouse’s 50% is not taxed because it was always theirs. This is different from the surviving spouse’s potential inheritance share, which is a separate calculation under the succession rules.

What happens if I don’t pay ITCMD?

You cannot complete the probate process. No notary will issue the inventory deed, and no judge will homologate the partition without proof of ITCMD payment. Additionally, the state tax authority (SEFAZ) can inscribe the debt in the divida ativa (active debt registry), leading to tax execution proceedings, asset liens, and restrictions on your CPF.

Is there ITCMD on life insurance proceeds?

Pure life insurance (seguro de vida) is not subject to ITCMD under CC Art. 794, which provides that insurance proceeds are not part of the estate. VGBL plans are generally treated as insurance for this purpose. PGBL plans, however, are typically treated as financial investments and ARE subject to ITCMD. The distinction depends on when contributions were made and the plan structure.

Does ITCMD apply to cryptocurrency?

The tax authorities treat cryptocurrency as a financial asset subject to ITCMD. The practical challenge is enforcement — states are still developing mechanisms to identify and value crypto holdings at the time of death. Crypto declared in the deceased’s annual tax return (DIRPF) will be included in the ITCMD base. Undeclared crypto creates both ITCMD and income tax exposure for heirs.

Can foreigners get ITCMD exemptions?

Foreigners are subject to the same exemptions as Brazilian citizens. There is no special treatment — positive or negative — based on nationality. The exemptions available depend on the state where the asset is located or where the inventory is processed.

How does ITCMD interact with the US estate tax?

There is no tax treaty between Brazil and the US covering estate/inheritance taxes. A US citizen dying with assets in both countries may face US federal estate tax (up to 40%) on worldwide assets AND ITCMD (up to 8%) on Brazilian assets. The US allows a foreign tax credit for estate taxes paid to foreign governments, but this credit does not eliminate double taxation — it only reduces it. Detailed analysis is available in our estate tax comparison guide.

Why ZS Advogados for ITCMD Planning?

ITCMD planning for foreigners sits at the intersection of Brazilian state tax law, federal succession rules, and international tax obligations. Getting it right requires fluency in all three — plus the practical ability to calculate ITCMD across different state scenarios, model the impact of LC 227/2026 progressive rates, and coordinate with US tax advisors on foreign tax credit claims. Zachariah Zagol — the first American admitted to the Brazilian Bar (OAB/SP 351.356) — has advised American and European clients on ITCMD planning across multiple states, including pre-reform restructuring, donation strategies, and holding company formations designed to minimize inheritance tax exposure.

Book your ITCMD planning consultation or explore our full estate planning guide.