Description
An adviser’s guide to why the matrimonial property regime must be identified before the U.S. gross estate can be sized; the three families of matrimonial property law and the statutory default regime of each Western European jurisdiction; the participation regimes of Germany and Switzerland and the German equalization claim at death; which law governs the regime of a couple that has relocated, under the EU Regulation, the Hague Convention, national conflict of law rules and the rules applied in a U.S. forum; the composition of the U.S. gross estate, the community property basis adjustment, the marital deduction and the qualified domestic trust; the estate tax treaties that address spousal transfers and community property; the gift tax and reporting consequences of a change of regime; and the practice points that follow.
30 pages. Updated in September 2026.