Download or read book EU Succession Regulation No 650 2012 written by Haris Pamboukis and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book EU Regulation on Succession and Wills written by Ulf Bergquist and published by Verlag Dr. Otto Schmidt. This book was released on 2015 with total page 390 pages. Available in PDF, EPUB and Kindle. Book excerpt: This concise article-by-article commentary discusses all the crucial points of the new EU Regulation No. 650/2012 of 4 July 2012 on cross-border estates, with particular focus on the following issues: the law applicable to a succession being the law of the State in which the deceased had his habitual residence at the time of death, which is also relevant for jurisdiction for contentious succession matters, election as to the applicable law, recognition and enforcement, authentic instruments, the European Certificate of Succession. This book turns the Regulation into an easily understandable text for all users, practitioners, academics or students and - authored by members of the experts group that formulated the Commission's draft proposal from six European countries - reflects perspectives from differing legal systems.
Download or read book EU Succession written by Haris Pamboukis and published by Beck/Hart. This book was released on 2017-06-15 with total page 752 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Union Succession Regulation No 650/2012 entered into force on 17 August 2015 covering all successions in European Union Members States (with the exception of Denmark, the United Kingdom and Ireland). The Regulation comprehensively covers the substantive succession law as well as the specific procedural law and the law concerning recognition and enforcement of the relevant judicial awards. The Regulation applies to ''cross-border“ succession i.e. cases where the citizen of one Member State died in another Member State where he or she owned movable or immovable assets. Based on the Regulation, the applicable law now follows uniform rules, meaning the historic legal fragmentation within Europe will be eliminated in the future. This magisterial new text offers a comprehensive analysis of the new regulation, providing an authoritative guide to the new European succession framework.
Download or read book The EU Succession Regulation written by Alfonso-Luis Calvo Caravaca and published by Cambridge University Press. This book was released on 2016-10-20 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Succession Regulation is a landmark in the field of EU private international law. It unifies the conflicts of laws, jurisdiction and recognition of foreign judgments and some other legal instruments in the field of succession and wills. This volume provides an article-by-article commentary on the individual provisions of the Regulation, introduced by an overview of its general framework and underlying principles. As a reference tool for the Regulation, this book is intended to promote a high standard of interpretation and application. With contributions from leading scholars in the field, it uses a comparative approach in its analysis to enrich the academic debate and highlight the problems likely to arise in the practical application of the Regulation.
Download or read book The State of Implementation of the EU Succession Regulation s Provisions on Its Scope Applicable Law Freedom of Choice and Parallelism Between the Law and the Courts written by and published by . This book was released on 2017 with total page 9 pages. Available in PDF, EPUB and Kindle. Book excerpt: Regulation (EU) No 650/2012 has governed successions opened since its entry into force on 17 August 2015. Soon after, some 200 000 people working as notaries across Europe were faced with these new rules, and it can already be said that the regulation's aims of legal certainty, predictability and simplification have for the most part been achieved. - This is certainly true from a private international law perspective; replacing 25 systems with one is a major step forward and, in the vast majority of cases, enables a single law to be applied to the succession as a whole. For successions with links to Member States only, problems have been relatively limited in so far as these States have since applied identical rules of conflict. Most problems have arisen primarily as a result of successions with links to third countries, including Denmark, Ireland and the United Kingdom, with their own conflict-of-law rules. Attempts were made to take this into account in the regulation by agreeing in particular to include a specific article on renvoi, which was welcomed. However in a large number of cases, this does not prevent the fragmentation of the succession. - Another problem has arisen with respect to notaries of certain Member States now being obliged to apply most times the law of another Member State, and thus raising specific issues of accessing legal content, especially if this law is of a third country, where previously a conflict rule would have resulted in the law of the forum being applied more often than not (at least for immovables), as is the case in France.
Download or read book The EU Succession Regulation written by Alfonso-Luis Calvo Caravaca and published by Cambridge University Press. This book was released on 2016-10-20 with total page 1476 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Succession Regulation is a landmark in the field of EU private international law. It unifies the conflicts of laws, jurisdiction and recognition of foreign judgments and some other legal instruments in the field of succession and wills. This volume provides an article-by-article commentary on the individual provisions of the Regulation, introduced by an overview of its general framework and underlying principles. As a reference tool for the Regulation, this book is intended to promote a high standard of interpretation and application. With contributions from leading scholars in the field, it uses a comparative approach in its analysis to enrich the academic debate and highlight the problems likely to arise in the practical application of the Regulation.
Download or read book Legacy by Vindication Under the EU Succession Regulation No 650 2012 Following the Kubicka Judgment of the ECJ written by Piotr Tereszkiewicz and published by . This book was released on 2019 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article explores the question of the 'recognition' of the material effects of legacies by vindication (legatum per vindicationem), if such legacies concern the right of ownership of immovable property located in an EU Member State the law of which does not provide for such legacies to have a direct material effect, such as Germany. The authors analyse this question in the light of the first judgement issued by the Court of Justice of the European Union on the European Union Regulation No. 650/2012 on Succession and Wills, the Kubicka case (C-218/16). The article's first part provides a brief account of legacies by damnation and legacies by vindication as they are found in the substantive succession laws of EU Member States. Subsequently, key notions arising under the EU Succession Regulation No. 650/2012 with respect to the recognition of legacies by vindication, such the general principle of unity, the registry exemption, the rights in rem exception as well as the adaption of rights in rem, are discussed. The article's final part maps out the implication of the Kubicka judgment for the theory and practice of European Succession Law.
Download or read book Disinheritance Against the EU Regulation on Succession No 650 2012 Polish Law Perspective written by Mariusz Załucki and published by . This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The disposition of disinheritance, which as part of the freedom of the assets disposition in the event of death, interferes with the legislative solutions protecting persons close to the deceased. This institution is not uniformly understood and regulated in national laws of the EU countries. Moreover, the legal systems of some those countries do not provide for disinheritance. Therefore, in connection with the entry into force of the EU Regulation No. 650/2012 on succession, the practical application of this institution appears to be problematic even at first glance. Therefore, the author believes that it seems necessary to present the disposition of disinheritance and the possible consequences of its use arising from the entry into force of the EU Regulation No. 650/2012 on succession. Because it is not possible to present all European solutions in one [scientific] article, the subject of author's presentation is the situation in which the law applicable to inheritance cases against the EU Regulation No. 650/2012 on succession is the Polish law.
Download or read book European Private International Law and Member State Treaties with Third States written by Nadjma Yassari and published by . This book was released on 2019 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the background, scope and practical impact of bilateral treaties and multilateral conventions concluded by selected Member States of the European Union with Third States, both from the European and the Third State perspective.
Download or read book International Succession written by Louis Garb and published by Oxford University Press, USA. This book was released on 2010 with total page 841 pages. Available in PDF, EPUB and Kindle. Book excerpt: Increasing numbers of people have connections with one country, but live and work in another, frequently owning property or investments in several countries. As such, international aspects arise in an increasing number of estates. Different countries may have separate arrangements for ownership, taxation, and succession. International Succession equips practitioners with the information necessary to navigate problems involving these different systems. Although lawyers would often advise only on the law of the jurisdictions in which they are based, seeking advice from lawyers in other countries, this book will save the practitioner the time - and expense - of ascertaining the basics concerning the inheritance systems in different countries, offering clear and easy to use information on the laws of inheritance and succession. Each country's report is based on responses to a comprehensive questionnaire that considers the practical issues arising from the jurisdiction's individual laws, making it easy for users to make specific comparisons between the laws of one country and another. The book covers over fifty countries with entries written by experts from each country, making it an invaluable resource for the busy practitioner. This title is an improved and expanded version of International Succession, edited by Louis Garb and published by Kluwer Law International, 2004. This edition, published in hardback form, will also be supplemented annually in between editions to update the individual country entries.
Download or read book The European Union After the Treaty of Lisbon written by Diamond Ashiagbor and published by Cambridge University Press. This book was released on 2012-04-16 with total page 345 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of some of the most controversial aspects of the European Union's Lisbon Treaty.
Download or read book Insights and proposals related to the application of the European succession regulation 650 2012 written by and published by . This book was released on 2019 with total page 437 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Brussels IIbis Regulation written by Ulrich Magnus and published by Walter de Gruyter. This book was released on 2012-04-26 with total page 545 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Will Regulation 650 2012 Simplify Cross Border Successions in Europe written by Mireia Artigot-Golobardes and published by . This book was released on 2018 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper addresses recent changes in European succession law brought about by the European Commission's "Regulation on jurisdiction, applicable law, recognition and enforcement of decisions in matters of succession." One of the most important issues that this Regulation addresses is the determination of the law applicable to a given succession for nationals of one member state with habitual residence in another member state. The Regulation provides that successions for those who die in this situation are governed by the law of the state in which they had their habitual residence at death. This paper questions whether the Regulation will simplify and reduce transaction costs in cross-border successions from two perspectives: First, from the perspective of whether the Regulation will increase or decrease the application of a given state's substantive succession law, and, second, from the perspective of the effect of its choice of laws rule on property entitlements given the variation in forced inheritance rules and clawback provisions across EU member states. These issues raise important questions about whether the Regulation will bring about the simplicity its drafters seek.
Download or read book Brussels I Regulation written by Ulrich Magnus and published by Walter de Gruyter. This book was released on 2011-12-27 with total page 1001 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Brussels I Regulation is by far the most prominent cornerstone of the European law of international civil procedure. Every practitioner in the international field has to work with it - and its importance is still growing. The first edition of this full scale article-by-article commentary found a very warm reception. This new edition brings the book up to date, incorporating a host of developments in the four years since ist first appearance, combines in-depth analysis with a genuine and truly European perspective, authored by top experts from all over Europe, covers the jurisprudence of the ECJ and of the Member States, and integrates thorough discussion of the pending proposal for a Brussels Ibis Regulation. This truly European commentary offers invaluable guidance for lawyers, judges and academics throughout Europe.
Download or read book The Rome III Regulation written by Sabine Corneloup and published by Edward Elgar Publishing. This book was released on 2020-02-28 with total page 365 pages. Available in PDF, EPUB and Kindle. Book excerpt: This comprehensive Commentary provides an in-depth, article-by-article analysis of the Rome III Regulation, the uniform rules adopted by the EU to determine the law applicable to cross-border divorce and legal separation. Written by a team of renowned experts, private international law scholars and practitioners alike will find this Commentary an incisive and useful point of reference.
Download or read book The Interaction Between Family Law Succession Law and Private International Law written by Jens Scherpe and published by European Family Law. This book was released on 2021-01-04 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book brings together a range of views on the reciprocal influences of substantive and private international law in the fields of family and succession law. It outlines some key elements of this interplay in selected jurisdictions and provides a basis for discussion and future work on the reciprocal influences of domestic and European law.
