International Aspects of Succession

Part 1 Introduction: the scope of the law of succession; the foreign element in the law of succession; the passing of the deceased's property; jurisdiction; recognition of foreign orders; staying proceedings; choice of law; specific connecting factors; the distinction between movable and immovable property; international unification. Part 2 Administration of estates: the process of dealing with an estate; grants of representation; administration; conclusion; the Hague Convention on the Administration of Estates. Part 3 Family protection: succession and matrimonial property; matrimonial property; the relationship between matrimonial property and succession; fixed limitations on testamentary power; discretionary limitations on testamentary power; general reform; conclusion. Part 4 Family relationships: introduction; marriage; legitimacy and legitimation; adoption. Part 5 Intestate succession: intestacy; where an intestate dies domiciled abroad; where an intestate dies domiciled in England; treatment of debts; property passing to the state. Part 6 Wills: introduction; the general rules; capacity; formal validity; essential validity; construction; revocation; election. Part 7 Powers of appointment: nature and classification; powers in the conflict of laws; capacity; formal validity; essential validity; construction; revocation. Part 8 Inter vivos dispositions: gifts inter vivos; donatio mortis causa. Part 9 Trusts: introduction; distinctions and terminology; jurisdiction; the recognition of Trusts Act 1987; variation of trusts; reclaiming trust property for the benefit of the settler's family. Part 10 Taxation: the form of taxation of property on death; the basis of taxation; foreign tax and double taxation; the non-enforcement of foreign revenue laws; relief from double taxation. Part 11 Conclusion: general structure; scission or unity; choice of connecting factor; conventions.