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|All Authors / Contributors:||
Audrey Cantarano; Cyrille David; Université de Paris-Dauphine,
|Description:||363 p. ; 30 cm|
|Responsibility:||Audrey Cantarano ; sous la direction de Cyrille David.|
Accounting of lifetime transfers, obligations in relation to forced heirship rules are key notions, which regulate families' inheritance entitlement upon the death of a donor. The death of a donor may also have impact on taxation. Well known in many countries, these notions are ruled under various regulations. We first compare the Laws of four different countries with regard to these notions, and then address the issues connected to the settlement of a donor in another country after a lifetime transfer. Then, we consider domicile and residence notions, examine to what extent Laws could have jurisdiction on lifetime transfers regarding their Account, the obligation to restore or reimburse such gifts, criteria for jurisdiction of Courts, and tax consequences. Regarding key notions of civil Law, we conclude that equity should - at least - lead to fix part of these duties, with respect to the law of the country of origin.