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Author: Bariatti, Stefania
Publisher: Edward Elgar Publishing
ISBN: 1785365304
Category : Law
Languages : en
Pages : 576
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Book Description
With cross-border successions becoming increasingly common in the context of the European Union, this timely book offers a systematic practical analysis of how cross-border successions should be treated, including examination of which courts may establish jurisdiction over succession disputes and which law governs such disputes. Studying cross-border successions in the context of estate planning and in the opening and liquidation of a succession, it examines the specificities of the European Certificate of Succession, contextualising it within its interface with the national laws and practice of EU Member States.
Author: Bariatti, Stefania
Publisher: Edward Elgar Publishing
ISBN: 1785365304
Category : Law
Languages : en
Pages : 576
Get Book
Book Description
With cross-border successions becoming increasingly common in the context of the European Union, this timely book offers a systematic practical analysis of how cross-border successions should be treated, including examination of which courts may establish jurisdiction over succession disputes and which law governs such disputes. Studying cross-border successions in the context of estate planning and in the opening and liquidation of a succession, it examines the specificities of the European Certificate of Succession, contextualising it within its interface with the national laws and practice of EU Member States.
Author: David J. Hayton
Publisher: Jordan Publishing (GB)
ISBN: 9780853088165
Category : Conflict of laws
Languages : en
Pages : 0
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Book Description
European Succession Laws is the definitive guide to succession law and estate administration in all of the major European jurisdictions, including cross-border succession issues under the Hague Conventions. Edited by a leading succession lawyer, and with contributions from each of the foreign jurisdictions, European Succession Laws provides expert guidance on European countries such as Austria, Belgium, Denmark, Ireland, Spain, and others.
Author: Ulf Bergquist
Publisher:
ISBN: 9783504384524
Category : Law
Languages : en
Pages : 0
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Book Description
This concise article-by-article commentary discusses all the crucial points of the new EU Regulation No. 650/2012 of 4 July 2012 on cross-border estates, with particular focus on the following issues: the law applicable to a succession being the law of the State in which the deceased had his habitual residence at the time of death, which is also relevant for jurisdiction for contentious succession matters, election as to the applicable law, recognition and enforcement, authentic instruments, the European Certificate of Succession. This book turns the Regulation into an easily understandable text for all users, practitioners, academics or students and - authored by members of the experts group that formulated the Commission's draft proposal from six European countries - reflects perspectives from differing legal systems.
Author: Alfonso-Luis Calvo Caravaca
Publisher: Cambridge University Press
ISBN: 9781107127302
Category : Law
Languages : en
Pages : 0
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Book Description
The European Succession Regulation is a landmark in the field of EU private international law. It unifies the conflicts of laws, jurisdiction and recognition of foreign judgments and some other legal instruments in the field of succession and wills. This volume provides an article-by-article commentary on the individual provisions of the Regulation, introduced by an overview of its general framework and underlying principles. As a reference tool for the Regulation, this book is intended to promote a high standard of interpretation and application. With contributions from leading scholars in the field, it uses a comparative approach in its analysis to enrich the academic debate and highlight the problems likely to arise in the practical application of the Regulation.
Author: Nadjma Yassari
Publisher:
ISBN: 9781780686646
Category : Conflict of laws
Languages : en
Pages : 0
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Book Description
This book analyses the background, scope and practical impact of bilateral treaties and multilateral conventions concluded by selected Member States of the European Union with Third States, both from the European and the Third State perspective.
Author: Maria Gigliola di Renzo Villata
Publisher: Springer
ISBN: 3319762583
Category : Law
Languages : en
Pages : 640
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Book Description
This book presents a broad overview of succession law, encompassing aspects of family law, testamentary law and legal history. It examines society and legal practice in Europe from the Middle Ages to the present from both a legal and a sociological perspective. The contributing authors investigate various aspects of succession law that have not yet been thoroughly examined by legal historians, and in doing so they not only add to our knowledge of past succession law but also provide a valuable key to interpreting and understanding current European succession law. Readers can explore such issues as the importance of a father’s permission to marry in relation to disinheritance, as well as inheritance transactions and private, dynastic and cross-border successions. Further themes addressed by the expert contributors include women’s inheritance rights, the laws of succession for the prince in legal consulting, and succession in the Rota Romana’s jurisprudence.
Author: Louis Garb
Publisher: Oxford University Press, USA
ISBN: 0199550271
Category : Language Arts & Disciplines
Languages : en
Pages : 841
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Book Description
Increasing numbers of people have connections with one country, but live and work in another, frequently owning property or investments in several countries. As such, international aspects arise in an increasing number of estates. Different countries may have separate arrangements for ownership, taxation, and succession. International Succession equips practitioners with the information necessary to navigate problems involving these different systems. Although lawyers would often advise only on the law of the jurisdictions in which they are based, seeking advice from lawyers in other countries, this book will save the practitioner the time - and expense - of ascertaining the basics concerning the inheritance systems in different countries, offering clear and easy to use information on the laws of inheritance and succession. Each country's report is based on responses to a comprehensive questionnaire that considers the practical issues arising from the jurisdiction's individual laws, making it easy for users to make specific comparisons between the laws of one country and another. The book covers over fifty countries with entries written by experts from each country, making it an invaluable resource for the busy practitioner. This title is an improved and expanded version of International Succession, edited by Louis Garb and published by Kluwer Law International, 2004. This edition, published in hardback form, will also be supplemented annually in between editions to update the individual country entries.
Author: Ilaria Viarengo
Publisher: Bloomsbury Publishing
ISBN: 1509919872
Category : Law
Languages : en
Pages : 975
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Book Description
This book is built upon the outcomes of the EUFam's Project, financially supported by the EU Civil Justice Programme and led by the University of Milan. Also involved are the Universities of Heidelberg, Osijek, Valencia and Verona, the MPI in Luxembourg, the Italian and Spanish Family Lawyers Associations and training academies for judges in Italy and Croatia. The book seeks to offer an exhaustive overview of the regulatory framework of private international law in family and succession matters. The book addresses current features of the Brussels IIa, Rome III, Maintenance and Succession Regulations, the 2007 Hague Protocol, the 2007 Hague Recovery Convention and new Regulations on Property Regimes. The contributions are authored by more than 30 experts in cross-border family and succession matters. They introduce social and cultural issues of cross-border families, set up the scope of all EU family and succession regulations, examine rules on jurisdiction, applicable law and recognition and enforcement regimes and focus on the current problems of EU family and succession law (lis pendens in third States, forum necessitatis, Brexit and interactions with other legal instruments). The book also contains national reports from 6 Member States and annexes of interest for both legal scholars and practitioners (policy guidelines, model clauses and protocols).
Author: Alfonso-Luis Calvo Caravaca
Publisher: Cambridge University Press
ISBN: 1316889351
Category : Law
Languages : en
Pages : 1476
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Book Description
The European Succession Regulation is a landmark in the field of EU private international law. It unifies the conflicts of laws, jurisdiction and recognition of foreign judgments and some other legal instruments in the field of succession and wills. This volume provides an article-by-article commentary on the individual provisions of the Regulation, introduced by an overview of its general framework and underlying principles. As a reference tool for the Regulation, this book is intended to promote a high standard of interpretation and application. With contributions from leading scholars in the field, it uses a comparative approach in its analysis to enrich the academic debate and highlight the problems likely to arise in the practical application of the Regulation.
Author: Haris Pamboukis
Publisher: Beck/Hart
ISBN: 9781509909957
Category : Law
Languages : en
Pages : 752
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Book Description
The European Union Succession Regulation No 650/2012 entered into force on 17 August 2015 covering all successions in European Union Members States (with the exception of Denmark, the United Kingdom and Ireland). The Regulation comprehensively covers the substantive succession law as well as the specific procedural law and the law concerning recognition and enforcement of the relevant judicial awards. The Regulation applies to ''cross-border“ succession i.e. cases where the citizen of one Member State died in another Member State where he or she owned movable or immovable assets. Based on the Regulation, the applicable law now follows uniform rules, meaning the historic legal fragmentation within Europe will be eliminated in the future. This magisterial new text offers a comprehensive analysis of the new regulation, providing an authoritative guide to the new European succession framework.
