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Comparative Succession Law
This third volume in a series on Comparative Succession Law concerns the entitlement of family members to override the provisions of a deceased person's will to obtain money or assets (or more money or assets) from the person's estate. Some countries, notably those in the civil law tradition (such as France or Germany), confer a pre-ordained share of the deceased's estate or of its value on certain members of the deceased's family, and especially on the deceased's children and spouse. Other countries, notably those in the common law tradition (such as England, Canada, or Australia), leave the matter to the discretion of the court, the amount awarded depending primarily on financial need. Whi...
The Oxford Handbook of Comparative Law
This fully revised and updated second edition of The Oxford Handbook of Comparative Law provides a wide-ranging and diverse critical survey of comparative law at the beginning of the twenty-first century. It summarizes and evaluates a discipline that is time-honoured but not easily understood in all its dimensions. In the current era of globalization, this discipline is more relevant than ever, both on the academic and on the practical level. The Handbook is divided into three main sections. Section I surveys how comparative law has developed and where it stands today in various parts of the world. This includes not only traditional model jurisdictions, such as France, Germany, and the Unite...
Migration from the Russian Empire: January 1888-May 1889
Compilation of data on passengers of Russian nationality who immigrated to the United States from Russian territories between 1875 and 1891. Passenger lists are arranged chronolgically by date of arrival at New York harbor.
Juristenzeitung
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Passing Wealth on Death
Introduction / Alexandra Braun and Anne Röthel -- Will-substitutes : a US perspective / Thomas P Gallanis -- Will-substitutes in Canada / Angela Campbell -- Will-substitutes in England and Wales / Alexandra Braun -- Will-substitutes in Scotland / Daniel Carr -- Will-substitutes in New Zealand and Australia / Nicola Peart and Prue Vines -- Will-substitutes in Italian law / Gregor Christandl -- Will-substitutes in French law / Cécile Pérès -- Will-substitutes in German law / Anatol Dutta -- Will-substitutes in Switzerland and Liechtenstein / Dominique Jakob -- Will-substitutes from the perspective of business owners / Susanne Kalss -- Will-substitutes from the perspective of (international) investors / Paul Matthews -- Will-substitutes and creditors : Canada and the US / Lionel Smith -- Will-substitutes : the perspective of creditors in Germany, and England and Wales / Reinhard Bork -- Will-substitutes and the claims of family members and carers / Jonathan Herring -- Will-substitutes and the family : a continental perspective / Anne Röthel -- Exploring means of transferring wealth on deat h: a comparative perspective / Alexandra Braun and Anne Röthel
Passing Wealth on Death
Wealth can be transferred on death in a number of different ways, most commonly by will. Yet a person can also use a variety of other means to benefit someone on death. Examples include donationes mortis causa, joint tenancies, trusts, life-insurance contracts and nominations in pension and retirement plans. In the US, these modes of transfer are grouped under the category of 'will-substitutes' and are generally treated as testamentary dispositions. Much has been written about the effect of the use of will-substitutes in the US, but little is generally known about developments in other jurisdictions. For the first time, this collection of contributions looks at will-substitutes from a compar...
