This article-by-article Commentary on EU Regulations 2016/1103 and 2016/1104 critically examines the uniform rules adopted by the EU to deal with the property relations of international couples, both married and in registered partnerships. Written by experts from a variety of European countries, it offers a comprehensive side-by-side discussion of the two Regulations to provide context and a deeper understanding of the issues of jurisdiction, applicable law and recognition of judgements covered.

Louisiana Matrimonial Regimes is designed to explore the features of the community property regime, often lauded as one of the most beautiful and significant achievements of the civil law tradition. The community property regime is widely accepted as the marital property regime of choice for an astonishing number of countries, including France, Germany, Spain, Brazil, and countless others. Even on American soil, where the common law tradition has generally been favored over that of the civil law, the community regime has gained significant sway. Nine of our states have rejected the English-inspired marital property regime in favor of the community. This book invites the reader to study the details of Louisiana's regime of patrimonial rights and duties between husband and wife, and also to consider comparisons with the matrimonial regimes of other civilian and Anglo-American systems. Andrea Beauchamp Carroll is the Donna W. Lee Professor of Family Law at the Louisiana State University Paul M. Hebert Law Center. Before joining the LSU Law faculty, Professor Carroll clerked for The Honorable W. Eugene Davis of the United States Court of Appeals for the Fifth Circuit. She subsequently worked as an associate at the Dallas law firm of Baker Botts, L.L.P., handling appellate litigation. In 2003, Professor Carroll returned home to LSU Law, where she has been teaching and writing about family law, community property, and property for the last eleven years. Professor Carroll is the author of more than a dozen books and articles in her field, and has recently been published in the Indiana, Tulane, Brooklyn, and Cardozo law reviews. Her Tulane article on civil law property was honored at the 2005 Stanford-Yale Junior Faculty Forum. Professor Carroll is also active in law reform in Louisiana, as a Member of the Council of the Louisiana State Law Institute and the Institute's Persons, Children's Code, and Adult Guardianship Committees. She led the comprehensive revision of Louisiana's community property law in the area of reimbursement rights in 2009, the first substantial revision of Louisiana's community property rules since 1979. And she led a successful reform of Louisiana's child relocation rules in 2010. As Reporter of the Law Institute's Marriage and Persons Committee, Professor Carroll continues to work to improve the law related to marriage and the family. Professor Elizabeth R. Carter is the Judge Anthony J. Graphia & Jo Ann Graphia Associate Professor of Law at the LSU Law Center, where she teaches and writes in the areas of matrimonial regimes, estates, trusts, and taxation. A graduate of Tulane University Law School and member of the Order of the Coif, Professor Carter graduated with the highest grade point average in the civil law curriculum and served as the research assistant to Professor A.N. Yiannopoulos. Her comment on Louisiana Civil Code article 466, published in Volume 80 of the Tulane Law Review, received the Dean Rufus C. Harris Award for the Best Writing on a Civil Law Subject. Professor Carter earned an LL.M. in Taxation from the University of Alabama. She also has degrees in biology and Spanish from the University of Memphis. She serves on several Louisiana State Law Institute committees and maintains a private estate-planning practice. She has two dogs and a husband, in that order.

The Principles of European Family Law - drafted by the Commission on European Family Law (CEFL) - contain models which may be used for the harmonization of family law in Europe. This book contains the Principles regarding property relations between spouses. In these Principles, the CEFL has developed an all-inclusive set of rules for two matrimonial property regimes: the participation in acquisitions and the community of acquisitions. Both regimes have been put on an equal footing. Each matrimonial property regime, whether it functions as a default or as an optional regime, is strongly connected with the rights and duties of the spouses and the possibility for them to make a marital property agreement. These issues have also been addressed by including two common chapters on the general rights and duties of spouses and on marital property agreements, which are to be applied regardless of which of the regimes applies. (Series: European Family Law - Vol. 33)