Succession of Multijurisdictional Estates: Conflict of Laws, Conflict of Jurisdictions and Substantive International Regulatory Treatment

An essential part of contemporary international civil law practice consists matters concerning succession multijurisdictional estates, which in turn accounts for the practical significance and relevance scientific study regulatory treatment respective matters. understanding subject matter conflict laws procedure is to effective estates clients who own assets or otherwise have significant contacts with more than one jurisdiction. The primary focus this article describe approaches resolving most typical problems on basis analysis legal doctrine, legislative enactments case foreign jurisdictions. author considers solving multinational particular: importance location a testator's assets, formal validity testamentary dispositions, establishment true domicile person, advantages disadvantages single will disposing property, etc. In context these analyses Regulation EU № 650/2012 European Parliament Council 4 July 2012 jurisdiction, applicable law, recognition enforcement decisions acceptance authentic instruments creation Certificate Succession; Convention 5 October 1961 Conflicts Laws Relating Form Testamentary Dispositions; 25 November 1973 providing Uniform Law an International Will.