Fast forward to today, and this precedent is suddenly relevant again. With the recent freezing of Russian oligarch assets following sanctions over Ukraine, the question of "probate for Russian nationals" has returned. If a sanctioned Russian billionaire dies while living in London or New York, their heirs will face the exact same wall Kirillin’s family did in 1978—except now, the stakes are in the billions, not thousands.
The first Soviet citizen to undergo probate proved a simple truth: Death is the one international equalizer. No matter which side of the Iron Curtain you lived on, you still can’t take it with you—and Uncle Sam still wants his estate tax. Have you ever dealt with an international probate case? Or do you have a Cold War family story involving frozen assets? Let me know in the comments. first of a soviet citizen to undergo probate
Under Soviet law at the time, private inheritance was tricky. The state claimed a significant chunk of an estate, and the bureaucratic hurdles to move money out of the U.S. and into the USSR were nearly insurmountable. Initially, the Soviet Consulate attempted to claim the funds on behalf of Kirillin’s family back in Moscow. But American banks refused to release the assets without a court order. The USSR argued that diplomatic immunity or consular notification should suffice. Fast forward to today, and this precedent is
The Manhattan Surrogate’s Court disagreed. The judge ruled that by living and working in New York—even as a foreign agent—Kirillin was subject to New York estate laws. The first Soviet citizen to undergo probate proved
But in 1978, a probate judge in New York City found himself at the epicenter of a diplomatic first. For the first time in history, the assets of a Soviet citizen—who had died in the United States—were officially recognized and processed through the American probate system.