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Clawback Law in the Context of Succession
Jayne Holliday
出版Bloomsbury Publishing, 2020-05-14
主題Law / InternationalLaw / Conflict of Laws
ISBN150993233X9781509932337
URLhttp://books.google.com.hk/books?id=ziDYDwAAQBAJ&hl=&source=gbs_api
EBookSAMPLE
註釋This book offers a global solution for determining the law applicable to a claim to clawback an inter vivos gift from a third party within the context of a succession. The book aims to identify an appropriate and applicable legal framework which supports legal certainty for cross-border estate planning and protects the legitimate expectations of the relevant parties. This is an area of private international law that has yet to be handled satisfactorily – as can be seen by the inadequate treatment of clawback from third parties in the 1989 Hague Convention on the Law Applicable to Succession to the Estates of Deceased Persons, and the 2012 EU Succession Regulation.