A unique event summarising the approaches in England, France and the US.
Should the spouses sign a document before the marriage?
- Situation by default in the absence of a pre-nup in your respective jurisdiction – what are generally the financial consequences by default in the event of a divorce in your jurisdiction?
- If parties decide to sign a pre-nup, which legal weight is given by the Courts to such document? Is it binding in your respective jurisdiction?
Should the parties sign a US prenuptial agreement, a French marriage contract or a UK prenuptial agreement? Should the parties sign a document in each country?
- Possibility in your jurisdiction to sign one document per country?
- If choice is made to select one jurisdiction and to make it work in other jurisdictions, which factors do you refer to choose this “main” jurisdiction?
Assuming that the choice has been made to enter into a foreign pre-nup (whether it is a pre-nup or post-nup), how to ensure recognition in your jurisdiction?
- Which rules of form for the signing of pre-nups and post-nups in your jurisdiction?
Which provisions to include in the foreign pre-nup or post-nup to ensure recognition in your jurisdiction?
- Which provisions are typically included? Only rules relating to the division of assets in the event of death or divorce or anticipation of all the financial consequences of the divorce?
- Which provisions from a foreign pre-nup or post-nup may not work in your respective jurisdiction?
The speakers who will provide an English, French an US perspective include:
Emilie Helm of Payne Hicks Beach, Delphine Eskenazi of Libra Advocats and Gretchen Beall Schumann of Rabin Schumann & Partners LLP
To book your place on the ThoughtLeaders4 HNW Divorce ‘Non, Je Ne Regrette Rien….Tips & Tricks for International Pre & Post Nups: A Comparative English, French & US Perspective’ webinar on 13 July 2021 from 6.00 pm 7.00 pm (UK time) click here