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]
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.
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.