A Mock Case of Cross-Border Inheritance
The complexity of legal issues that arise when deciding which judge has jurisdiction and which law is applicable in a cross-border succession case might be better understood by looking at a detailed, albeit made- up, example of one. For our mock case, let us imagine a California-based married couple in which the husband is an […]
The Settlors’ Choice of Law in Italian-American Cross-Border Successions
In the area of estate planning, common law jurisdictions typically afford much more discretion to the individual to design a scheme of distribution. Conversely, civil law systems (such as Italy’s) have statutes that tend to be long, detailed, and allow for less discretion on the part of the settlor and the court. In Italy, statutes […]