Star-crossed lovers - matrimonial property regimes in cross-border estates. 2 February 2022
As it becomes easier and increasingly common for roving married clients to acquire assets in various jurisdictions around the world, advisors need to understand the matrimonial property regimes that may affect succession and property rights of such clients’ estates.
Without such understanding, neither planning nor estate administration will be successful. The property rights of married clients can depend on their domicile at either spouse’s death, the domicile at the time of their marriage, the situs of the asset in question or a combination of these factors depending on the jurisdiction where the estate is administered.
Our program will explore one such itinerant couple and how four jurisdictions (California, France, Mexico and the UK) would approach the administration of such couple’s assets on death.
- Jeannette Yazedjian-Karlin & Peebles LLP
- Sangna Chauhan-Charles Russell Speechlys UK
- Anne Guichard-Notaires 3 Turbigo
- Jose Massas Farell-Basham
For technical issues: Kristin Beane, [email protected]