Vanderbilt Journal of Transnational Law

First Page



The need to coordinate succession laws of different nations was recognized as early as 1893 at the first Hague Conference where attempts were begun to coordinate the laws of succession on death through multilateral conventions. Notwithstanding so early an effort, however, the administration of multinational estates has remained plagued by diversity of national laws governing succession on death. The resulting confusion and inefficiency of administration has often frustrated the testamentary intentions of decedents of many nationalities. While no viable uniformity has been attained among nations, the need for consistency increases. Half a million United States civilian citizens live abroad, and three million aliens live in the United States. Given the current trends in immigration to the United States, in world-wide expansion of United States trade and industry, and in exploitation of the United States market by foreign producers, this number will undoubtedly continue to increase, as will the need to administer multinational estates. In response to this need, efforts continue to be made through proposed multinational conventions to coordinate succession laws of nations, and recent United States participation in such efforts, make success of the undertaking more likely in the near future.