The great mobility of people and capital in the world today means that the likelihood of a person acquiring and dying with assets in more than one jurisdiction is probably greater than ever. As a result an English lawyer is now more and more likely to encounter a multinational estate. This book aims to examine the international aspects of succession primarily from the perspective of an English lawyer, but utilising in addition to English cases and materials, cases and materials from other common law jurisdictions, particularly Australia, Canada and New Zealand. The body of case law and materials from these jurisdictions forms a valuable resource for dealing with common problems. They also form the basis for an evaluation of developments in the subject generally and the possible impact of conventions designed to achieve uniformity in the rules of private international law relating to succession.
This examination will be of interest to practitioners as well as to those concerned with the subject in an academic environment.