Webinar: Civil law and common law - Comparison of estate administration on death. 2 June 2021
- 07.00 Los Angeles, Vancouver
- 09:00 Mexico City
- 10.00 New York, Toronto
- 11.00 São Paulo
- 14:00 GMT/UTC
- 15.00 London
- 16.00 Berlin, Paris
- 18.00 Abu Dhabi
- *Convert other timezones
With increasing globalisation of people and their assets, common law practitioners and advisors need to know more about how an estate is administered in civil law countries, and likewise, civil law practitioners and advisors need to know more about how an estate is administered in common law countries. Yet there is a general lack of understanding on these issues, including on key legal differences between the two legal regimes, but as well on a practical basis, what actually happens in carrying out an estate administration under each regime.
This webinar will join together common law and civil law speakers who will discuss key differences between the two legal cultures, and then explore them on a practical basis using a case study involving an estate administration with both elements.
Speakers will explore the following issues:
- Testamentary freedom versus forced heirship and the impact of each on estate administration
- The probate process and the role and authority of the executor versus “seisin” - immediate vesting in the heirs and the role of an administrator or similar
- Types of wills including formal wills, holograph wills and notarial wills
- Use of testamentary trusts versus general absence of domestic trusts
- Assets of the estate and impact of matrimonial regime: separation of property versus community of property.
- MODERATOR: Margaret O’Sullivan TEP, Managing Partner, O’Sullivan Estate Lawyers LLP, Toronto-Canada
- Brian Cohen TEP, Partner, Gowling WLG, Toronto-Canada
- David Stevens TEP, Partner, Gowling WLG, Toronto-Canada
- Alessandro Belluzzo TEP, Partner, Belluzzo International Partners, London-UK
- Andrea Moja TEP, Partner, Belluzzo International Partners, London-UK and Milan-Italy
A live webinar accessible by web (both for audio and visuals) from your computer, tablet or smartphone. In a designated session towards the end, attendees will have the opportunity to ask live questions of the speakers.
To join the webinar at the designated time, prior registration is required.
Following registration, registrants will receive an email containing instructions for joining the webinar.