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BOOK REVIEW
INTERNATIONAL SUCCESSION
3rd edition
Edited by Louis Garb and John Wood
ISBN: 978-0-19-955027-2
Oxford University Press
www.oup.com
“WE ARE ALL INTERNATIONAL LAWYERS NOWADAYS!”
An appreciation by Phillip Taylor MBE and Elizabeth Taylor of Richmond Green Chambers
So say Louis Garb and John Wood in this excellent third edition in the OUP stable of international publications. This is a splendid resource, not only for the modern private client lawyer, but also for litigants and academic alike.
The authors make a bald statement at the beginning “we live in an increasingly globalized world”! Yes, and they have produced a book of relevance to this age which explores assets on death and what happens to them in the globalized world.
Cross-border trade between nations, intermingling and intermarriage between persons of different nationalities, living and working abroad and investing within multiple jurisdictions; these are only some of the complexities surrounding the deposition of assets in a globalized world. So when someone in possession of multiple assets in multiple jurisdictions dies, who succeeds to what assets on death where?
As the editors note in the preface, ‘to a significant extent, the rules of succession in any particular jurisdiction are unique to that jurisdiction.’ And as Paul Mathews of the School of Law, Kings College, London observes in the foreword, ‘It is not enough to know the basic differences between systems. We must have access to points of detail and quickly’ – a task which the useful and valuable ‘International Succession ‘ undertakes admirably.
In its more than 800 pages plus glossary, the relevant inheritance law and practice in fifty jurisdictions around the world are explained by professional lawyers from each of them. In order to compare like with like, the contributors have been asked by the editors to base their exposition on a common questionnaire (the full text of which is cited) to ensure exact comparison by covering exactly the same points. (Especially interesting in a UK context are the differences between English and Scots law, particularly on intestacy.) The book, in other words, is a joint venture between the general editors and the contributors, each of whom are listed individually with contact details.
If you are involved with international clients , either as a private lawyer, litigator, academic, or possibly an individual grappling with cross-border succession issues, which can be tortuously complex, this book will save you incalculable amounts of time. As mobility increases and business goes truly global, Garb & Wood’s meticulously researched work is an invaluable acquisition in any law library.