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The Transfer of Property in the Conflict of Laws

The Transfer of Property in the Conflict of Laws
Author: Janeen M. Carruthers
Publisher: Oxford Private International L
Total Pages: 0
Release: 2005
Genre: Law
ISBN: 9780199271474

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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 oflaws.


Transfer of Ownership in International Trade

Transfer of Ownership in International Trade
Author: Alexander von Ziegler
Publisher: Kluwer Law International B.V.
Total Pages: 506
Release: 2011-01-01
Genre: Law
ISBN: 9041131345

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Including law from Australia, Austria, Brazil, Canada, Chile, China, Denmark, England, Finland, France, Germany, India, Italy, Japan, Republic of Korea, Netherlands, Norway, Russia, South Africa, Spain, Sweden, Switzerland, And United States of America (U.S.A.)


Transfer of Movable Property Under U.S. Law

Transfer of Movable Property Under U.S. Law
Author: Martin Lilja
Publisher: Peter Lang Gmbh, Internationaler Verlag Der Wissenschaften
Total Pages: 0
Release: 2014
Genre: Personal property
ISBN: 9783631649428

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The book discusses legal rules for three functional commercial conflict situations under the laws of the U.S.A. (the U.C.C. etc.) on the protection of a buyer in the seller's insolvency, the protection of a seller in the buyer's insolvency, and the conflict between a person formerly entitled to the goods and a good faith acquirer.


Commentaries on the Conflict of Laws, Foreign and Domestic, in Regard to Contracts, Rights, and Remedies, and Especially in Regard to Marriages, Divorces, Wills, Successions, and Judgments

Commentaries on the Conflict of Laws, Foreign and Domestic, in Regard to Contracts, Rights, and Remedies, and Especially in Regard to Marriages, Divorces, Wills, Successions, and Judgments
Author: Joseph Story
Publisher: The Lawbook Exchange, Ltd.
Total Pages: 584
Release: 2007
Genre: Conflict of laws
ISBN: 1584777737

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"An Epoch in the Law" The first systematic work on the subject and an indisputable legal classic, Story's Commentaries on the Conflict of Laws synthesized the standard sources of the day, both Anglo-American and Continental, analyzed them with great skill and arranged them in an accessible manner. It was held in high respect in North America, Great Britain and Europe and went through eight editions. Joseph Story [1779-1845] became the youngest Associate Justice of the Supreme Court of the United States in 1811 and in 1829 was appointed the first Dane Professor of Law at Harvard Law School. An important educator who played a key role in the law school's development, he wrote several influential treatises, such as the landmark Commentaries on the Constitution (1833). ..". [i]t is not too much to say that its publication constituted an epoch in the law; for it became at once the standard and almost the sole authority...[it also] received the honor of being practically the first American law book to be cited as authority in English courts."--Charles Warren, A History of the American Bar 545 CONTENTS List of Authors cited List of Cases cited I. Introductory remarks II. General Maxims of International Jurisprudence III. National Domicil IV. Capacity of Persons V. Marriage VI. Marriage - Incidents to VII. Foreign Divorces VIII. Foreign Contracts IX. Personal Property X. Real Property XI. Wills and Testaments XII. Succession and Distribution XIII. Foreign Guardianships and Administrations XIV. Jurisdiction and Remedies XV. Foreign Judgments XVI. Penal Laws and Offences XVII. Evidence and Proofs Index


Commentaries on the Conflict of Laws, Foreign and Domestic, in Regard to Contracts, Rights, and Remedies, and Especially in Regard to Marriages, Divorces, Wills, Successions, and Judgments

Commentaries on the Conflict of Laws, Foreign and Domestic, in Regard to Contracts, Rights, and Remedies, and Especially in Regard to Marriages, Divorces, Wills, Successions, and Judgments
Author: Joseph Story
Publisher:
Total Pages: 966
Release: 1841
Genre: Conflict of laws
ISBN:

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Commentaries on the conflict of laws, foreign and domestic, in regard to contracts, rights, and remedies, and especially in regard to marriages, divorces, wills, successions, and judgments

Commentaries on the conflict of laws, foreign and domestic, in regard to contracts, rights, and remedies, and especially in regard to marriages, divorces, wills, successions, and judgments
Author: Joseph STORY (One of the Justices of the Supreme Court of the United States.)
Publisher:
Total Pages: 598
Release: 1834
Genre:
ISBN:

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Separation and Abstraction in Property Transfers

Separation and Abstraction in Property Transfers
Author: Zhicheng WU
Publisher: BRILL
Total Pages: 285
Release: 2023-05-08
Genre: Law
ISBN: 9004547932

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This book argues that there are three dividing lines regarding modes and consequences of property transfers which should not be conflated by comparative lawyers, namely, intent alone versus intent plus, unitary approach versus separatist approach, and causality versus abstraction. Unlike Chinese law, English law takes a non-unified approach not only in the stage of transfer but also in the stage of restitution, where the consequence in relation to the property right transferred under a flawed underlying basis can be purely causal, purely abstract, and abstract in common law but causal in equity. Nevertheless, abstraction is normatively more justifiable than causality.