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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 4/2021: Abstracts

Conflict of Laws

Choice of law by the testator is particularly important and a notary should point not only at the present situation, but also at possible developments in the future. The position of the surviving spouse under § 1371 BGB in German law has become a highly debated subject and here the aspect of free movement of persons is highlighted.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 3/2022: Abstracts

Conflict of Laws

Hay : On the Road to a Third American Restatement of Conflicts Law. American private international law (Conflict of Laws, “Conflicts Law”) addresses procedure (jurisdiction of courts, recognition of judgments) as well as the choice of the applicable law. In Case C-490/20, V.M.A., In Case C-490/20, V.M.A.,