International Succession Law: A Guide to Administration of a Cross-Border Estate

When a person dies owning assets in multiple jurisdictions, complex issues are liable to arise in liquidating the estate. Conflicts of laws arise because different countries apply different connecting factors for determining the law to govern the administration of an estate. Relevant connecting factors are domicile, habitual residence, nationality and situs. Where a testator dies leaving assets in countries applying different connecting factors for determining the applicable law, the question necessarily arises as to how the conflicting rules are to be reconciled, harmonised and applied. Further complicating the administration of estates is the fact that many jurisdictions have different rules for the devolution of movable and immovable property.

This book addresses the plethora of issues to be addressed in the context of administering a cross-border estate. It examines a multiplicity of topics including the UNIDROIT, Hague and Council of Europe Conventions, the EU Succession Regulation 650/2012 ("Brussels IV"), connecting factors, renvoi, scissionist & unitary regimes, matrimonial property regimes, double taxation estate treaties, federated estates and transfer of title. It sets forth practical examples and case studies from a diversity of jurisdictions to illustrate the operation of the different concepts which impact on the devolution of property in a cross-border context.. The final chapter of the book provides a step-by-step guide to the administration of a multijurisdictional estate.

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The text comprises two volumes, the main text (Volume 1) and a companion text, comprising narrative summaries and bullet point overviews (Volume 2).

 

Hard Copy: .€240

​E-Format: €200

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