US expatriate persons and property owners, the European Union Succession Regulation and the choice of New York law

Abstract The EU Succession Regulation represents perhaps the most ambitious and comprehensive effort to date to regularize the rules about choice of law that apply to the succession of decedents' estates in any part of the world. The Article highlights the significance of the Regulation not only in planning for U.S. persons who live in the European Union, but also in planning for U.S. persons who live outside the European Union but who own property there. The Article also discusses the reception that a choice of law made under the Regulation may be expected to receive in New York State–one of the most prominent jurisdictions of the United States where issues of cross-border succession planning constantly arise and for which the Regulation may be especially relevant.