Details
- Provides a comprehensive survey of succession laws in fifty countries
- Enables easy cross-referencing with a questionnaire format for each country
- Considers the practical issues arising out of inheritance across multiple jurisdictions
- Entries written by experienced practitioners in the relevant jurisdiction around the world
- Previously a Kluwer Law International title, International Succession edited by Louis Garb, 2004
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 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.
Readership: This book will appeal to solicitors and barristers specialising in private client whose practice involves work with an international element. This will include solicitors working in private practice or in-house in banks and trust companies; barristers; and trust managers working in banks and trust companies. It is likely also to have secondary markets among judges, notaries, consulates, and registrars of civil status.
- Contents:
- Foreword
- Preface
- Table of Contents
- List of Contributors
- Questionnaire
- Glossary
- Note: The European Union Wills and Succession Harmonization ProjectFrancis Barlow QC:
- 1: Juan Pablo McEwan: Argentina
- 2: John De Groot, Kate McQueeney: Australia
- 3: Merran Loewenthal, Dr Friedrich Schwank: Austria
- 4: Petra Hanna-Weekes, Andrea Williams: Bahamas
- 5: Michal Bolle: Belgium
- 6: Michael McAuley: Bermuda
- 7: Adriana Camargo Rodrigues: Brazil
- 8: Christopher McKenzie: British Virgin Islands
- 9: Archie Rabinowitz, Lori Duffy, Clare Burns: Canada - Ontario
- 10: Charles Gagnon: Canada- Quebec
- 11: Justin Appleyard, Maxine Bodden: Cayman Islands
- 12: Graeme Johnson, Han Yun: China
- 13: Lefkios Tsikkinis, Mariorita Neocleous: Cyprus
- 14: Ulrik Gronborg: Denmark
- 15: John Wood: England and Wales
- 16: Frank Lipworth, Jean-Pierre Le Bouffo: France
- 17: Heinz Bauer: Germany
- 18: Theodora Karagiorgou: Greece
- 19: St. John Robilliard: Guernsey
- 20: Wendy Lam: Hong Kong
- 21: Lait Bhasin: India
- 22: John Gill: Ireland
- 23: John Rimmer: Isle of Man
- 24: Louis Garb: Israel
- 25: Andrew Paton: Italy
- 26: Tomoki Debari, Koji Kawamata: Japan
- 27: Tony Fulton: Jersey
- 28: Stefan Wenaweser: Liechtenstein
- 29: Nicole Wee: Malaysia
- 30: Clara Borg: Malta
- 31: Julieta Ovalle Piedra, Raoul Rodriguez-Walters: Mexico
- 32: Ian Edge: Middle East Overview
- 33: Donald Manasse: Monaco
- 34: Mathijs ten Wolde, Bert Nannen: The Netherlands
- 35: Pravir Tesirm: New Zealand
- 36: Neil Bleakley, Wendy Carberry: Northern Ireland
- 37: Aftab Khan: Pakistan
- 38: David Arosemena: Panama
- 39: Telma Carvalho: Portugal
- 40: Alan Eccles: Scotland
- 41: Jr Flax, D Hutchison: South Africa
- 42: Jorge Capell, Jorge Hernandez: Spain
- 43: Elisabeth Olsson: Sweden
- 44: Tina Wustemann: Switzerland
- 45: Nigel Li, Sophia Yeh, Josephine Peng, J C Liu: Taiwan
- 46: Orhan Yavuz Mavioglu: Turkey
- 47: Amjad Ali Khan: United Arab Emirates
- 48: G Warren Whitaker: United States - New York
- 49: Patrick McCabe, Sonja Johnson: United States - California
- 50: Juan Antunez, Michele Maracini: United States - Florida
- AppendixComparison Table
Louis Garb, Solicitor, Louis Garb & Co., and John Wood, Consultant, Herbert, Smith LLP
"This is a splendid resource, not only for the modern private client lawyer, but also for litigants and academics alike... Garb and Wood's meticulously researched work is an invaluable acquisition in any law library." - Phillip Taylor MBE, Richmond Green Chambers
