John Donaldson, the Tasmanian-born father of Denmark's Queen Mary, died on 11 April 2026 in Hobart at the age of 84, prompting renewed interest across Australia in cross-border estate planning for families with international ties.
The Life Behind the Royal Connection
John Dalgleish Donaldson was born in Scotland on 5 September 1941 and emigrated to Australia, building a distinguished career as a professor of applied mathematics. He obtained his PhD from the University of Tasmania in 1967 and later taught at the Korea Advanced Institute of Science and Technology (KAIST). His daughter, Mary Donaldson, met Crown Prince Frederik of Denmark in Sydney in 2000 and went on to become Queen Mary of Denmark when Frederik was crowned King Frederik X.
Queen Mary visited her father in Hobart at the end of March 2026 as his health declined. A private family memorial service has been planned in Australia. His death — widely covered by Australian media — has put a spotlight on a legal challenge that many Australians with overseas family connections face: what happens to your estate when beneficiaries live in different countries?
Why Cross-Border Estates Are Complicated
When an Australian dies with assets in multiple countries, or with beneficiaries who are foreign nationals or residents, the estate administration can become significantly more complex than a standard Australian probate process.
Different countries apply different rules about which jurisdiction's laws govern an estate. Australia generally follows the rule that the law of the country where an asset is located (lex situs) governs how that asset is distributed. This means if an Australian holds property in Spain, Danish law may not automatically protect a Danish-resident beneficiary's interests — Australian and Spanish probate rules would apply instead.
For families like the Donaldsons, where members are spread across Australia, Denmark and other countries, executors must navigate multiple legal systems simultaneously. According to the Australian Government's MoneySmart guidance on wills and estates, failing to make an explicit will can leave cross-border estates tied up in administration for years.
Key issues that arise in cross-border estates include:
- Domicile determination: Which country's laws govern the distribution of personal property depends on where the deceased was domiciled — their permanent home. An expatriate who moved to Australia decades ago but maintained strong ties to Scotland may have unclear domicile.
- Double taxation: Estate or inheritance taxes may be levied in more than one country. Australia has no federal inheritance tax, but beneficiaries receiving assets from Australian estates may face inheritance duties in their home countries.
- Recognition of foreign grants of probate: An Australian grant of probate may not automatically be recognised in another country, requiring resealing or fresh applications abroad.
- Currency and asset transfer: Moving assets internationally after death involves foreign exchange considerations, transfer taxes and banking regulations that vary by jurisdiction.
What a Wealth Management Expert Can Do for You
A wealth management professional with experience in cross-border estate planning can help Australians navigate these complexities before a crisis arises. The goal is to structure assets and documentation in a way that minimises friction for beneficiaries wherever they live.
Key steps a specialist might recommend include:
- Drafting jurisdiction-specific wills. Rather than relying on a single will to govern all assets globally, many estate planners recommend separate wills for each country where significant assets are held. Each will must be carefully drafted to ensure they complement rather than revoke one another.
- Establishing a trust structure. For families with significant assets and international beneficiaries, a properly structured trust can streamline distribution and provide tax planning opportunities.
- Reviewing beneficiary designations. Superannuation, life insurance and investment accounts often pass outside the will entirely. If a beneficiary is a non-resident, there may be additional withholding tax obligations or restrictions.
- Updating estate plans after major life events. Marriages, divorces, deaths, relocations overseas and changes in asset portfolios all warrant a review of existing estate documents.
The Donaldson family's situation is a reminder that even a straightforward Australian estate can become internationally complicated when family members have built lives across different continents. Planning well in advance — rather than leaving it to executors under pressure — makes an enormous difference.
Disclaimer: Estate planning involving international assets and beneficiaries carries significant legal and tax complexity. This article is informational only and does not constitute legal or financial advice. Consult a qualified wealth management professional or estate planning lawyer for guidance specific to your circumstances.
When Should You Seek Advice?
If any of the following apply to you, it is worth consulting a wealth management expert now rather than leaving the details to your family later:
- You hold property, investments or bank accounts outside Australia
- Your children, spouse or other beneficiaries live overseas or hold foreign citizenship
- You have recently moved to Australia from another country and retain assets in your home country
- You have remarried and have children from a previous relationship living in a different country
- Your estate includes superannuation, trusts or business interests with international components
The death of John Donaldson — a private man who happened to be the father of a queen — serves as a poignant reminder that the complexity of an estate has nothing to do with fame. Any Australian family with international ties faces the same questions. Getting expert advice early is the most valuable gift you can leave behind.
On ExpertZoom, Australian-based wealth management professionals can help you review your estate planning needs, including international considerations. A consultation now can save your beneficiaries significant time, cost and distress later.
