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EUGENE F. SCOLES* INTRODUCTORY BACKGROUND The problems presently confronting th e survivors of persons who die owning assets outside th e nation of which they are both a citizen an d resident are unnecessarily difficult to predict, costly to resolve and impose a severe economic burde n on th e recipients of property at death. The seemingly simple question of who are th e heirs and what shares they take in the family property of the decedent has proven most difficult just because of th e uncertainty of determining the na tion whose law would apply to provide th e answer. This results from the difference in rules of private international law (conflict of laws) applied by many nations under the civil law and those rules applied by nations under Anglo-American common law concepts. * EUGENE F. SCOLES is Max L. Rowe Professor of Law Emeritus, University of Illinois; Distinguished Professor of Law Emeritus, University of Oregon; United States Delegate to The Hague Conference on Private International Law, Special Com mission on Decedents Estates (1986-1988). The views expressed herein are those of the author and do not necessarily reflect the views of th e United States Department of State.
American Journal of Comparative Law – Oxford University Press
Published: Jan 1, 1994
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