When the Matrimonial Property Regime Becomes Cross-Border: Which Law Applies, and Which Connecting Factor at Which Date? When a matrimonial property regime becomes cross-border—because the spouses have different nationalities, live in different countries over time, or hold assets in more than one jurisdiction—the core question is often: which law governs the property regime? The answer […]
Maintenance (Alimony) and Child Custody in Mixed Marriages: Applicable Law and Conflicts of Jurisdiction In mixed marriages—where spouses have different nationalities, the family’s habitual residence changes across borders, or the marital life is closely connected to more than one state—the most sensitive part of a divorce file is often maintenance (alimony) and child custody. This […]