Canadian living abroad - How should I get a prenup?

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I’m a Canadian citizen currently living and working in the U.S. on a work visa. My fiancée is also Canadian and will be joining me in the U.S. after we get married.

I currently live in New York, but there’s a possibility we may move to California in the future. Longer term, we may also eventually return to Ontario.

We are getting legally registered/married in Canada, and the wedding is on July 20, so I realize we’re on a tight timeline. I know I should have started this earlier.

My fiancée and I have already discussed getting a prenup/marriage contract, and she is fully onboard. We’ve also discussed the high level terms and generally agree on what we think is fair.

What is the best way to proceed given the cross-border situation? Since we’re getting married in Canada, should we each get Canadian/Ontario family lawyers and have an Ontario marriage contract drafted?

Or, since we’ll be living in the U.S. after marriage and may end up in New York or California, should we be using U.S. lawyers instead?

Would the best approach be something like:

  • Ontario lawyer drafts the marriage contract
  • my fiancée gets her own Ontario lawyer for independent legal advice
  • a New York lawyer reviews it
  • possibly a California lawyer reviews it as well

Posted Jun 8, 2026, 4:34 PM UTC

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