Carruthers Janeen M.: The Transfer of Property in the Conflict of Laws
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Жанр : Oxford University Press
Издательство : Oxford University Press
Год издания : 2005
Аннотация:
- A detailed and modern examination of the choice of law rules in inter vivos transfers of property — Analyses relevant principles under both English and Scottish law — Covers an area of current interest and topicality, including cultural property and indirectly held securities — Offers balanced solutions to complex problems arising in choice of law rules related to property This book provides a detailed and up-to-date exposition of English and Scottish rules of choice of law in inter vivos transfers of property. It traces the development of the lex situs rule, and its application to inter vivos dealings with immovable property, tangible movable property (including the special case of cultural property), and intangible movable property (including indirectly held securities). The author offers two alternative models of suggested choice of law rules in property, introducing a greater degree of flexibility into choice of law rules in property, and formulates even-handed solutions to the complex problems of space, time and policy which arise in this area of the conflict of laws.