The EU Regulation Brussels IV: a Comparative Study between the Succession Law of the United States and Italy

5 Baku St. U. L.Rev. 194 (2019)
Article language: English.

The European Union continues to shape rules and norms on a global level and offers a rich and diverse economic, political and cultural environment. Indeed, European countries constitute an attractive business location for a large number of individuals and companies. On the level of the individual citizen of the EU and elsewhere, this EU-effect has resulted in an increase of bi-national marriages. Such developments often result in conflicts of jurisdiction and conflicts in applicable laws regarding inheritances. The present paper is an informative tool for international wealth planning lawyers who deal with succession planning for clients that either reside in a European Union Member State, are married to an EU citizen, or hold assets in the EU by providing an insight on the EU Succession Regulation, No. 650/2012. Indeed, the regulation might indirectly apply to individuals residing in States of the U.S.A. pursuant to the key provisions of Articles 20 and 36. The present analysis deals not only with issues of jurisdiction, recognition and enforcement of court judgments and applicable law, but also with the acceptance of notarial deeds, the formal and substantial validity of testamentary dispositions and other succession agreements.

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