Comparative Guide to Family and Estates Law

Master’s students at the Université de Paris X – Nanterre have produced a comparative guide that provides an overview of the legal situation in 70 countries on issues relating to:

  • nationality, adoption, marriage and divorce
  • estates
  • international private law

The guide is written in French.

[Source: Précisément.org, un blog pour l'Information juridique]

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Comments

  1. Bold of them to tackle family law, particularly to have included Canada. I’ve taken a very quick look and they get a fair bit wrong as far as Canada’s concerned (leaving aside the issue that they’ve got Quebec as a separate “pays” — for obvious tendentious reasons). One problem right off the top is the age for marriage, which, on the one hand they describe rightly as a “condition de fond” and on the other set out wrongly as following provincial legislation. As I say, this is easy stuff to punt, so I’m not surprised: I’d guess that most Canadian lawyers couldn’t get our marriage law right.

  2. On the topic of conflicts of law and family law, there was an exceedingly interesting survey in the Economist a couple of weeks ago, looking at the different consequences for equalization of property and spousal support depending on where a divorce is adjudicated. This is a major issue for wealthy couples with ties to multiple jurisdictions.