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Title Passing wealth on death : will-substitutes in comparative perspective / edited by Alexandra Braun and Anne Röthel
Published Oxford ; Portland, Or. : Hart Publishing, An imprint of Bloomsbury Publishing Plc, 2016

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Description 1 online resource
Series Studies of the Oxford institute of European and comparative law ; v. 22
Contents Introduction / Alexandra Braun and Anne Röthel -- Will-substitutes : a US perspective / Thomas P Gallanis -- Will-substitutes in Canada / Angela Campbell -- Will-substitutes in England and Wales / Alexandra Braun -- Will-substitutes in Scotland / Daniel Carr -- Will-substitutes in New Zealand and Australia / Nicola Peart and Prue Vines -- Will-substitutes in Italian law / Gregor Christandl -- Will-substitutes in French law / Cécile Pérès -- Will-substitutes in German law / Anatol Dutta -- Will-substitutes in Switzerland and Liechtenstein / Dominique Jakob -- Will-substitutes from the perspective of business owners / Susanne Kalss -- Will-substitutes from the perspective of (international) investors / Paul Matthews -- Will-substitutes and creditors : Canada and the US / Lionel Smith -- Will-substitutes : the perspective of creditors in Germany, and England and Wales / Reinhard Bork -- Will-substitutes and the claims of family members and carers / Jonathan Herring -- Will-substitutes and the family : a continental perspective / Anne Röthel -- Exploring means of transferring wealth on death h: a comparative perspective / Alexandra Braun and Anne Röthel
Summary Wealth can be transferred on death in a number of different ways, most commonly by will. Yet a person can also use a variety of other means to benefit someone on death. Examples include donationes mortis causa, joint tenancies, trusts, life-insurance contracts and nominations in pension and retirement plans. In the US, these modes of transfer are grouped under the category of 'will-substitutes' and are generally treated as testamentary dispositions. Much has been written about the effect of the use of will-substitutes in the US, but little is generally known about developments in other jurisdictions. For the first time, this collection of contributions looks at will-substitutes from a comparative perspective. It examines mechanisms that pass wealth on death across a number of common law, civil law and mixed legal jurisdictions, and explores the rationale behind their use. It analyses them from different viewpoints, including those of owners of businesses, investors, as well as creditors, family members and dependants. The aims of the volume are to show the complexity and dynamics of wealth transfers on death across jurisdictions, to identify patterns between jurisdictions, and to report the attitudes towards the different modes of transfer in light of their utility and the potential frictions they give rise to with policies and principles underpinning current laws
Analysis Will substitutes
Notes Includes papers presented at a conference held 27 and 28 March 2015 at Lady Margaret Hall in Oxford
Bibliography Includes bibliographical references and index
Notes Print version record and CIP data provided by publisher; resource not viewed
Subject Inheritance and succession -- Congresses
Estate planning -- Congresses
Property law.
LAW -- Administrative Law & Regulatory Practice.
Estate planning.
Inheritance and succession.
Genre/Form Conference papers and proceedings.
Form Electronic book
Author Braun, Alexandra, editor
Röthel, Anne, editor
LC no. 2016011741
ISBN 9781509907366
150990736X
9781509907373
1509907378
184946698X
9781849466981