Do Advance Medical Directives and wills set up in the U.S. work for us here in Mexico?

Tom and Susan from Northern California

Hi Ángel, We are here for the duration. Originally, we were coming down for a few weeks and now find ourselves in the category of people “who came for a week, and never left.” Our question is: we have our Advance Medical Directives, DNRs, family trust, and wills all set up in the U.S. Do any of those work for us here in Mexico?


Hello Tom and Susan, Thank you for your question as it seems to be posted on a weekly basis. Have you heard the saying “what happens in Vegas, stays in Vegas?” Well, the situation is similar in that assets in the United States are governed by American estate laws and assets in Mexico are governed by Mexican law. The easy and quick answer is “No.” Your American documents governing assets in the United States will not work here. I recommend you use your medical directives and DNRs as guides for the attorney whom you choose to draw up your Mexican documents.

Elena from Denver, Colorado

Hi Ángel, This is off subject, but I am trying to figure out the formula for giving my help their Christmas vacation pay. Is there an easy and up-to-date way to comply without having to hire someone to calculate it for me?


Hello Elena, It’s like you read my mind. I will be interrupting the series on estate planning and medical directives next week to explain how to calculate the Christmas vacation pay which we refer to in Spanish as the aguinaldo. Please check in next week for a user-friendly guide to the aguinaldo.

Ricardo from Los Angeles California

Hi Ángel, I own some property in Mazatlán through a bank trust. Can it be included in my will as I own the rights to the property but not the property itself?


Hello Ricardo, Absolutely. The bank trust, known in Spanish as a “Fidecomiso,” names you as the beneficiary or buyer of the property; it is transferable, rentable, and inheritable, as much as it is sellable. Secondary beneficiaries can be established within the trust to establish automatic inheritance of the property in case of death of the first beneficiary. A second layer to protect the beneficiary against being contested is to have a will. All passings in Mexico go through probate so an additional layer of protection simply ensures that your property and patrimony harmoniously goes to your intended beneficiary.

Thank you for your questions this week. For more specific information on AFTERLIFE™, Wills, Advance Directives, Legacy Bequeathments, Asset Protection, Real Estate closings, and all Notarial Services please contact the author: Ángel Marín Díaz at or 4151219005

Leave a Reply