Iran.

The Islamic Republic of Iran operates a codified Sharia-based succession system rooted in the Twelver Shi’a (Ja’fari) school of Islamic jurisprudence. Civil Code Articles 861–949 codify faraid compulsory shares — reflecting the doctrinal differences between Shi’a and Sunni inheritance jurisprudence (Shi’a law preferring lineal descendants over collaterals more strongly than Sunni law). Testamentary disposition (vasiyyat) is limited to one-third of the estate under Article 843 Civil Code, consistent with Twelver Shi’a fiqh.

Iran imposes inheritance tax under a progressive regime, with reduced rates for the surviving spouse and direct descendants and higher rates for more distant heirs. Real-property succession is registered through the Iranian land-registration system. Cross-border succession involving Iran is significantly complicated by international sanctions regimes — particularly OFAC and Canadian SEMA measures — affecting repatriation of Iranian-situs estate proceeds and family-wealth transfers.

The memoranda in this series address the recurring fact patterns in Iranian cross-border estate planning — including Twelver Shi’a faraid distinctions from Sunni doctrine, the vasiyyat one-third rule, real-property succession in Iran by foreign nationals and Iranian dual citizens, sanctions compliance for Iranian-source estate proceeds, the substantial Iranian-Canadian and Iranian-American diaspora succession planning needs, and the absence of estate-tax treaties with Canada and the United States.