English Trusts and Turkish Forced Heirship: Reserved Shares, Reduction Actions and Where the Assets Sit

Many Turkish families now live part of their lives in London. The children study in England, a house is bought in Kensington or Hampstead, a portfolio is managed by a London bank, and the family company stays in Istanbul. When the founder starts to plan for the next generation, an English trust is often the first structure proposed.

English law gives a settlor wide freedom. It has no fixed shares for children or a spouse, and a properly made lifetime trust takes the assets out of the settlor's estate. Turkish law starts from the opposite position. A Turkish citizen who leaves descendants, parents or a spouse can freely dispose of only part of the estate. The rest is protected as a reserved share (saklı pay), and transfers that encroach on it can be cut back by a court in a reduction action (tenkis davası).

Families ask whether an English trust protects the assets against a Turkish reserved-share claim. The answer depends on four things: which court decides, where each asset is located, the settlor's nationality and domicile, and how and when the trust was made.

This article explains how Turkish and English law each approach the question, where the two systems meet and where they do not, and which planning steps make a trust more robust. It builds on our guide to family business succession in Türkiye, which deals with ownership and control of the company itself.

1. Two legal systems ask different questions about the same estate

Turkish and English courts start from different connecting factors.

A Turkish court applies Article 20(1) of the Law on International Private and Procedural Law, Law No. 5718 (MÖHUK). Succession is governed by the national law of the deceased, and Turkish law always applies to immovable property in Türkiye. Article 4(1)(b) adds that, where a person has several nationalities including Turkish nationality, Turkish law applies. In a Turkish court, a Turkish citizen or a dual Turkish–British citizen is subject to Turkish succession law, reserved shares included, wherever that person lived.

The position changes if the deceased held only British nationality at death. The Turkish court then looks to the national law of the United Kingdom, and Article 2(5) MÖHUK leaves the choice between the legal systems of the United Kingdom to United Kingdom law, which for a person domiciled in England points to English law. English law has no reserved shares, although Turkish law would still govern land in Türkiye. Nationality is rarely changed for succession reasons alone, but the point matters for family members who have already given up Turkish citizenship.

An English court asks about domicile, not nationality. Succession to movable property, such as bank accounts, investment portfolios and company shares, is governed by the law of the country where the deceased was domiciled at death. Succession to land is governed by the law of the place where the land is. In Changizi v Mayes [2024] EWHC 6 (Ch), the testator was domiciled in Spain, and the court accepted that English law governed his will so far as it disposed of English leasehold property. The later sale of that property did not change the position.

Domicile in this sense is a common law concept. It is not the same as residence, and it is not the residence test that UK inheritance tax has used since 6 April 2025. Everyone receives a domicile of origin at birth, which for a person born in Türkiye is Turkish. A domicile of choice in England requires residence there together with an intention to remain permanently or indefinitely. An existing domicile is presumed to continue until a change is proved, and in Barlow Clowes International Ltd v Henwood [2008] EWCA Civ 577 the Court of Appeal described the domicile of origin as tenacious. Long residence in London is not enough on its own.

The consequence is that one estate can receive two different answers. A Turkish citizen who has lived in London for twenty years and intends to stay may be domiciled in England for an English court. A Turkish court will still apply Turkish succession law to the same person.

2. The reserved share protects descendants, parents and the spouse

Article 505 of the Turkish Civil Code, Law No. 4721 (TMK), provides that a person who leaves descendants, parents or a spouse may dispose by will only of the part of the estate outside the reserved shares. A person who leaves none of these relatives may dispose of the whole estate. Siblings lost their reserved share when Article 506 was amended by Law No. 5650 in 2007.

The reserved share is a fraction of the statutory share. Under Article 506, it is half the statutory share for descendants and a quarter of it for each parent. For a surviving spouse, it is the whole statutory share where the spouse inherits alongside descendants or parents, and three quarters in other cases.

An example makes the figures clearer. A married father of two children dies. Under Article 499, the spouse's statutory share is a quarter of the estate, and the children share the remaining three quarters. The spouse's reserved share is the whole quarter. The children's reserved share is half of three quarters, or three eighths. Together, five eighths of the estate are reserved, so the father could freely dispose of three eighths, which is 37.5 per cent. A widower survived only by children could dispose of half.

The calculation is not limited to what the deceased owned at death. Article 507 deducts debts, funeral costs and certain other items. Article 508 then adds back lifetime gratuitous transfers, to the extent they are subject to reduction. That is how a trust funded years before death can enter the calculation.

The reserved share is not enforced automatically. A disposition that exceeds the disposable part remains effective unless an heir brings a reduction action under Article 560 or raises reduction as a defence.

3. Which lifetime transfers a Turkish court can reduce

Article 565 TMK lists the gratuitous lifetime transfers that are subject to reduction in the same way as dispositions on death. It contains four categories.

The first covers lifetime transfers made on account of the inheritance to a statutory heir who later loses that status. It also covers transfers of assets or releases of debt to descendants made on terms that they need not be returned, and unusual dowries and establishment capital. The second covers transfers made to settle inheritance rights in advance. The third covers gifts that the donor could freely revoke, and all gifts made in the year before death other than customary presents. The fourth covers transfers that were evidently made to circumvent the reserved-share rules.

These categories translate directly into the drafting of a trust. A revocable trust falls within the third category however long ago it was made, because the settlor kept the right to take the assets back. An irrevocable trust funded in the last year of the settlor's life falls within it as well. An irrevocable trust funded years earlier can be reduced only under the fourth category. The heir then has to prove that the purpose of defeating the reserved shares was evident, so the reasons recorded when the trust was made carry real weight.

Reduction follows a fixed order. Under Article 570, dispositions on death are reduced first. Lifetime transfers come next, starting with the most recent and moving back in time until the reserved shares are met. A trust funded long before death is reached only if the estate and later gifts are not enough.

The person who received a reducible transfer has to give back the excess. Under Article 566, a recipient in good faith returns only what remains of the benefit when the succession opens. A recipient in bad faith is liable under the rules that apply to a possessor in bad faith. Article 567 adds that, where the deceased took out life insurance for a third party, the surrender value of the policy at death is subject to reduction. That matters for structures built around insurance policies.

4. Turkish law has no trust, so a Turkish court will reason by analogy

Türkiye is not a party to the 1985 Hague Convention on the Law Applicable to Trusts and on their Recognition. The United Kingdom gave that Convention the force of law through the Recognition of Trusts Act 1987. Turkish law has no equivalent institution, and we have not found a published decision of the Court of Cassation (Yargıtay) on how an English trust is treated in a reduction action.

Faced with a trust, a Turkish court would look at it through Turkish categories. The settlor transfers assets to the trustee without consideration, which is the defining feature of a gift under Article 285 of the Turkish Code of Obligations, Law No. 6098 (TBK). It would be surprising for an English trust to receive more protection than a Turkish foundation (vakıf), the closest Turkish institution. Article 108 TMK expressly preserves the right of a founder's heirs and creditors to sue under the rules on gifts and dispositions on death. Article 372 allows a family foundation only for purposes such as the education, establishment and support of family members. It prohibits tying property to one line of descent from generation to generation.

The uncertainty lies in the remedy more than in the principle. The trustee holds legal title, while the beneficiaries receive the benefit, and Turkish law has no settled answer on which of them is the proper defendant. A careful claimant will name both the trustee and any beneficiary who has received distributions, and trustees should plan on that basis.

5. A Turkish court can hear the claim wherever estate assets are in Türkiye

Under Article 43 MÖHUK, succession cases are heard by the court of the deceased's last domicile in Türkiye. If the last domicile was abroad, they are heard by the court where assets of the estate are located. Take a Turkish citizen who died domiciled in London but left a flat in Istanbul, a Turkish bank account or shares in a Turkish company. Proceedings over that estate can be brought in Türkiye.

Assets in Türkiye are also where a Turkish judgment is easiest to enforce. If the trust holds shares in a Turkish company or real estate in Türkiye, a reduction judgment can be enforced against those assets without the help of any foreign court. Immovable property in Türkiye is always subject to Turkish succession law under Article 20(1) MÖHUK, whatever the owner's nationality.

Holding Turkish land through a trust raises a further difficulty. Under Article 35 of the Land Registry Law No. 2644, companies incorporated abroad may acquire land in Türkiye only under special laws, so an English trustee company cannot usually be registered as owner. In practice, Turkish property in a trust structure tends to sit in a Turkish company whose shares the trustee holds. The Turkish land registry does not record trusts. Turkish law treats a transfer to someone who is to hold it for another as a fiduciary transfer (inançlı işlem): ownership passes in full, and the transferor keeps only a contractual claim, which the Court of Cassation's unifying decision of 5 February 1947 (No. 20/6) requires to be proved in writing. A Turkish court is unlikely to treat assets registered in a trustee's name as a separate trust fund.

The judge and trust scholar David Hayton made the same point about forced heirship claims against trusts generally. Where assets are within the reach of a civil law court, "territorial might prevails", and that court can make them available to forced heirs whether or not its country has implemented the Convention.

6. In an English court, a valid lifetime trust of English assets will usually stand

The Recognition of Trusts Act 1987 sets out the Hague Convention in its Schedule. Article 11 requires a trust created under its applicable law to be recognised as a trust, with the trust property forming a separate fund. Article 4 leaves outside the Convention the preliminary question of whether assets were validly transferred to the trustee.

Article 15 then preserves the mandatory rules of the law designated by the forum's own conflict rules on certain matters. They include succession rights, and especially the indefeasible shares of spouses and relatives. Article 15 does not mean that every forced heirship claim succeeds. It refers back to the conflict rules of the court hearing the case, and it separately preserves the rules on the transfer of title to property.

Under English conflict rules, a lifetime gift of assets in England that is valid under English law is not part of the donor's estate on death. The law governing the succession therefore does not reach it. Hayton's analysis of the Convention draws exactly this distinction. Common law courts treat valid gifts of assets located in common law countries as outside the estate. Civil law courts, by contrast, treat such gifts as available to satisfy forced shares.

We have not found an English decision applying a Turkish reserved-share claim to a lifetime English trust. The analysis above reflects the general rules and the leading commentary. Until a court decides the point, families should treat it as a strong position rather than a certainty.

7. A trust the settlor still controls is exposed in both systems

Trusts for founders often reserve powers to the settlor. The settlor may keep the right to revoke, to appoint and remove trustees, to direct investments or to add beneficiaries, and may also be a beneficiary. Article 2 of the Hague Convention accepts that reserving certain rights and powers is not necessarily inconsistent with the existence of a trust.

A Turkish court is likely to be less forgiving. A reserved power of revocation brings the trust within the third category of Article 565 TMK, whenever it was made. Wider control can also support an argument that the transfer was never meant to take effect as written. Under Article 19 TBK, a contract is characterised and interpreted according to the parties' real and common intention, disregarding words used to conceal their true purpose. That provision is the basis of the Turkish law on simulated transactions (muvazaa).

Turkish heirs have a further remedy where a gift is disguised as something else. In its unifying decision of 1 April 1974 (E. 1974/1, K. 1974/2), the Court of Cassation held that heirs may sue to cancel a transfer of land that the deceased made to look like a sale in order to deprive them of their inheritance. That remedy is not confined to reserved heirs. A transfer of Turkish land into a structure, recorded as a sale at a price that is never paid, would invite exactly that claim.

English law reaches a comparable result through the doctrine of the sham trust, under which documents that do not reflect what the parties actually intended are disregarded. In both systems, a trust that leaves the settlor in practical control of the assets is the easiest one to attack. The protection a trust offers grows with the independence of the trustee.

8. Assets that pass on death are treated differently

The protection described above applies to assets that left the settlor's estate during lifetime. Assets that the settlor still owns at death, including assets left to a trust by will, are part of the succession.

For those assets, an English court applies the law of the domicile to movables and the law of the place to land. If a Turkish citizen dies domiciled in Türkiye and leaves English bank accounts or investments to a trust by will, the English court will apply Turkish law, reserved shares included, to the succession to those movables. English land passes under English law, as Changizi v Mayes confirms.

The line between movables and land can be counterintuitive. Shares in a company are movables, even if the company's main asset is land. In Al-Thani v Al Thani [2024] UKPC 35, the Privy Council, applying common law principles, held that shares in a British Virgin Islands company passed under the law of the deceased's domicile, which was Qatar. For an owner domiciled in Türkiye, holding a London house through a company can bring Turkish succession law into play where holding it directly would not.

9. A Turkish reduction judgment does not reach a London trustee on its own

Türkiye and the United Kingdom have no treaty on the recognition of judgments. The 2019 Hague Judgments Convention, which has applied in the United Kingdom since 1 July 2025, does not help. Türkiye is not a party to it, and it does not apply to wills and succession in any event.

A Turkish judgment can therefore be enforced in England only at common law. That requires a final judgment for a sum of money against a defendant who was present in Türkiye or who submitted to the Turkish court. The Supreme Court confirmed the presence and submission rule in Rubin v Eurofinance SA [2012] UKSC 46. An English trustee with no presence in Türkiye that does not take part in the Turkish proceedings is generally outside that rule.

Trustees served with Turkish proceedings face a real decision. Defending the claim on the merits may amount to submission, which would allow the Turkish judgment to be enforced against them in England. Under section 33 of the Civil Jurisdiction and Judgments Act 1982, appearing only to contest jurisdiction does not count as submission, a point explained in our article on parallel proceedings between Istanbul and London. Ignoring the proceedings has its own cost if the trust holds assets in Türkiye.

Trustees do not have to take that decision alone. Under Part 64 of the Civil Procedure Rules and Practice Direction 64B, they can ask the English court for directions on whether to defend or pursue litigation. Such applications are listed in private in the first instance. The application must be supported by the advice of an appropriately qualified lawyer on the prospects of success, and by estimates of the value at stake and the likely costs. Where the litigation is in Türkiye, that means Turkish-law advice, prepared with the English application in mind.

The same limits apply in the other direction. An English judgment upholding the trust would need recognition in Türkiye under Articles 50 and 54 MÖHUK. Those provisions require reciprocity and exclude judgments that are clearly contrary to Turkish public policy or given in matters within the exclusive jurisdiction of the Turkish courts. Our guide to enforcing foreign judgments and arbitral awards in Türkiye explains those conditions.

10. An English domicile brings a different family claim

If the settlor dies domiciled in England and Wales, the English court does not apply fixed shares at all. It applies the Inheritance (Provision for Family and Dependants) Act 1975. Under section 1, a spouse or civil partner, a child and certain other family members and dependants can ask the court for reasonable financial provision from the estate. The court has a discretion and looks at needs, resources, obligations and conduct, not at a fixed fraction.

An application must normally be made within six months of the grant of representation, under section 4. Section 10 lets the court reach some lifetime gifts. It applies where the deceased made a disposition less than six years before death, with the intention of defeating an application under the Act, and without full valuable consideration. The court may then order the recipient to provide money or property for the applicant.

Moving to London does not make family claims disappear. In an English court, it replaces the Turkish reserved share with a discretionary English claim. In a Turkish court, Turkish law continues to apply to a Turkish citizen.

11. A worked example

Take a Turkish citizen, whom we will call Mr A. He has lived in London for fifteen years and intends to stay. He is married and has two adult children, one of whom is estranged. He owns a house in London worth £4 million and an investment portfolio with a London bank worth £6 million. In Istanbul he holds a 60 per cent stake in the family company, worth £5 million, and a flat worth £1 million.

In 2027, Mr A settles an irrevocable English discretionary trust with the portfolio and the company shares. He dies in 2034, leaving the house and the flat to his wife by will. The estranged son receives nothing and wants to claim.

In a Turkish court, the son can sue in Istanbul, where the flat is located, and Turkish law applies because his father was a Turkish citizen. His reserved share is three sixteenths of the calculation base. If the trust cannot be reduced, the base is the £5 million estate and his share is about £940,000. If he proves that the trust was evidently meant to defeat the reserved shares, the trust fund is added back, the base rises to £16 million and his share to £3 million. The bequests under the will are reduced first, and whatever cannot be met from them is claimed from the trust as the most recent lifetime transfer.

That claim against the trust can be enforced in Türkiye against the company shares, which are located there. It cannot be enforced in England against the London portfolio unless the trustee submitted to the Turkish court.

If an English court accepts that Mr A was domiciled in England, English law governs the succession to the London house, while the Istanbul flat passes under Turkish law as the law of the place where it is. The trust stands. The son could apply under the 1975 Act within six months of the grant. Because the trust was made more than six years before death, however, section 10 cannot reach it.

That domicile cannot be taken for granted. If the court found instead that he had kept his Turkish domicile of origin, the son would have no claim under the 1975 Act, and any movables left in the estate would pass under Turkish law. The lifetime trust of English assets would still stand.

The lesson is that the company shares are the exposed part of the structure, and the London assets are robust in England. The reasons recorded in 2027 for setting up the trust would also decide whether the son can bring the trust into the Turkish calculation at all.

12. Measures that make a trust more robust

The most reliable tool is Turkish rather than English. Under Article 528 TMK, a person can agree with a prospective heir that the heir renounces the inheritance, with or without consideration. The heir loses heir status, and a renunciation against consideration also binds the heir's descendants unless the agreement says otherwise. Under Article 545, the agreement must be made in the form of an official will, with both parties signing before the official and two witnesses. An heir who has renounced has no reserved share to claim in Türkiye, so the trust no longer depends on how a court characterises it.

Without a renunciation, the safest course is to fund the trust within the disposable part of the estate and to keep valuations from the time of funding. Under Article 507, the disposable part is calculated on the estate as it stands at death, so a trust that fits comfortably when it is funded can exceed it later if the rest of the estate shrinks. A margin and a periodic review are prudent. The trust should be irrevocable, because a reserved power of revocation brings it within Article 565 whenever it was made. Funding should not be left to the last year of life. The reasons for the trust, such as continuity of the family company or the care of a dependent child, should be recorded when it is made, because they bear directly on the fourth category of Article 565.

The location of assets deserves the same attention as the trust deed. Assets in Türkiye remain within reach of a Turkish judgment, whatever structure holds them. For that reason, some families leave Turkish assets to pass under a Turkish will that respects the reserved shares, and keep the trust for assets outside Türkiye.

Wills in both countries should be coordinated. Türkiye and the United Kingdom are both parties to the 1961 Hague Convention on the form of testamentary dispositions, which Article 1(2) MÖHUK preserves in Türkiye and section 1 of the Wills Act 1963 reflects in England. Under it, a will is valid in form if it complies with the law of the place where it was made, or with the law of the testator's nationality, domicile or habitual residence. An English will and a Turkish will should each say which assets they cover, so that neither revokes the other by accident.

Disinheritance is not an alternative. Under Articles 510 and 512 TMK, a reserved heir can be disinherited only for serious grounds stated in the will, such as a grave offence against the testator or a serious breach of family law duties. Estrangement is not in itself a ground, and a disinheritance that fails leaves the heir with the reserved share.

13. Tax is a separate layer in both countries

Since 6 April 2025, UK inheritance tax has been based on long-term residence rather than domicile. A person is a long-term UK resident if they were UK resident for at least ten of the twenty tax years before the year of the charge. Foreign assets held in a trust are generally excluded property only if the settlor, and in some trusts the beneficiary, is not a long-term UK resident at the time of the event. UK assets remain within the tax, and so do certain indirect interests in UK residential property. A person who leaves the UK after long residence remains within the tax for between three and ten years.

The United Kingdom has inheritance tax treaties with ten countries, and Türkiye is not one of them. Unilateral relief may still be available where the same assets are taxed in both countries.

On the Turkish side, Article 1 of the Inheritance and Transfer Tax Law, Law No. 7338, taxes the transfer by inheritance or gratuitous transfer of property belonging to Turkish citizens, including property abroad. It excludes a foreigner who is not resident in Türkiye and acquires a Turkish citizen's property outside Türkiye. How these rules apply to the settlement of a trust and to later distributions should be confirmed with tax advisers in both countries before the trust is funded.

14. Questions to settle before the trust is signed

The first question is who the settlor's reserved heirs are today, and who they may be at death. A marriage, a divorce or the birth of a grandchild changes the shares. The second is the settlor's nationality and domicile, because they decide which court applies which law. A dual citizen is treated as a Turkish citizen in Türkiye, whatever an English court may conclude about domicile.

The third question is where each asset is and whether it should be in the trust at all. Turkish real estate and shares in Turkish companies are exposed to Turkish judgments, and English land and English movables are treated differently on death. The fourth is whether any heir will sign a renunciation, and on what terms.

Finally, the trust deed, the letter of wishes, the wills and the corporate documents of any family company should tell one consistent story. A reduction action is decided on documents, often a decade after they were signed. Our guide to shareholders' agreements in family and founder-led companies explains how the company's own documents can support the plan.

Conclusion

An English trust is a powerful structure, but it does not remove assets from Turkish forced heirship by itself. A Turkish court applies Turkish succession law to Turkish citizens. It can reduce revocable trusts, trusts funded in the last year of life and trusts evidently made to defeat the reserved shares.

An English court sees the same structure differently. A valid lifetime trust of English assets is generally outside the succession, and a Turkish judgment against a trustee in England is enforceable only if the trustee was present in Türkiye or submitted. Assets that pass on death, and assets located in Türkiye, are treated differently.

How strong the structure is depends on decisions taken at the start. They include the renunciation of reserved heirs where possible, irrevocability, timing, a record of genuine purposes, and a clear view on which assets should be inside the trust.

How Terziolu & Partners Can Assist

Terziolu & Partners advises Turkish families and their advisers on Turkish succession law within our real estate and private client work. That covers reserved shares and reduction actions, renunciation agreements, Turkish wills and the treatment of foreign structures in Turkish proceedings. We also act for heirs and for trustees in succession disputes before the Turkish courts.

Where a plan involves an English trust, English assets or proceedings in both countries, the Turkish and English steps are coordinated between Istanbul and London through our cross-border legal coordination work, with appropriately qualified counsel in each jurisdiction. That includes the Turkish law evidence that English courts and trustees need. Contact us to review a trust, a will or a claim that involves both countries.

Selected Legislation, Authorities and Materials

Türkiye

Turkish Civil Code No. 4721 (TMK): Articles 108 (rights of a founder's heirs and creditors), 372 (family foundations), 499 (surviving spouse), 505 to 508 (disposable part and reserved shares), 510 and 512 (disinheritance), 528 (renunciation agreements), 545 (form of inheritance contracts), 560 (reduction action), 565 to 567 (lifetime transfers, restitution and life insurance), 570 (order of reduction) and 571 (time limits).

Law No. 5650 of 4 May 2007 amending the Turkish Civil Code: abolition of the reserved share of siblings (Article 506).

Law on International Private and Procedural Law No. 5718 (MÖHUK): Articles 1(2) (international conventions), 2(5) (states with more than one legal system), 4 (multiple nationality), 20 (succession), 43 (jurisdiction in succession cases), 50 and 54 (enforcement of foreign judgments).

Turkish Code of Obligations No. 6098 (TBK): Articles 19 (real and common intention; simulated transactions) and 285 (definition of a gift).

Land Registry Law No. 2644: Article 35 (acquisition of land by foreign nationals and by companies incorporated abroad).

Court of Cassation, Grand General Assembly on the Unification of Judgments, 5 February 1947, No. 20/6: fiduciary transfers and the requirement of written proof.

Court of Cassation, Grand General Assembly on the Unification of Judgments, 1 April 1974, E. 1974/1, K. 1974/2: transfers of land disguised as sales to deprive heirs (muris muvazaası).

Inheritance and Transfer Tax Law No. 7338: Article 1 (scope).

Hague Conference on Private International Law, status tables: 1985 Trusts Convention; see also the 1961 Convention on the form of testamentary dispositions and the 2019 Judgments Convention.

United Kingdom

Recognition of Trusts Act 1987: Schedule, Articles 2, 4, 11 and 15 of the Hague Trusts Convention.

Inheritance (Provision for Family and Dependants) Act 1975: sections 1 (applications), 3 (matters to which the court has regard), 4 (time limit) and 10 (dispositions intended to defeat applications).

Civil Procedure Rules, Part 64 and Practice Direction 64B: applications by trustees for directions, including whether to defend or pursue litigation.

Wills Act 1963, section 1: formal validity of wills.

HMRC Inheritance Tax Manual, IHTM47001: long-term UK residence test; and IHTM27161: inheritance tax conventions.

Barlow Clowes International Ltd v Henwood [2008] EWCA Civ 577: domicile of origin, domicile of choice and the presumption of continuance.

Changizi v Mayes [2024] EWHC 6 (Ch): English immovables of a testator domiciled abroad pass under English law as the law of the place.

Al-Thani v Al Thani [2024] UKPC 35: company shares are movables for succession purposes and pass under the law of the domicile.

Rubin v Eurofinance SA; New Cap Reinsurance Corp v Grant [2012] UKSC 46: enforcement of foreign judgments at common law on the basis of presence or submission.

David Hayton, The Hague Convention on Trusts (Bermuda, 23 May 2012): Article 15 and forced heirship claims against trust assets.