학술논문

Irish domiciled testator with assets located in Ireland, England and Wales - one will or two?
Document Type
Journal Article
Author
Source
I.P.L.J. 2013, 1(1), 2-5
Subject
Applicable law
Comparative law
Inheritance tax
Ireland
Overseas assets
Wills
Succession
Conflict of laws
Legal systems
Tax
Language
English
ISSN
0000-0000
Abstract
dvises on whether an Irish domiciled testator with assets in both Ireland and England and Wales requires separate wills in the two jurisdictions, including: (1) the applicable law rules in this scenario; (2) the succession regimes in each jurisdiction; (3) the circumstances in which an Irish will may be recognised in England and Wales; and (4) inheritance tax issues.

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