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Problems Of Conflict Of Laws On The Issue Of Inheritance Between Those Of Different Religions Under The Algerian Law: Analytical Study, M’Hamedi Bouzina Amina Nov 2022

Problems Of Conflict Of Laws On The Issue Of Inheritance Between Those Of Different Religions Under The Algerian Law: Analytical Study, M’Hamedi Bouzina Amina

مجلة جامعة الإمارات للبحوث القانونية UAEU LAW JOURNAL

What is established in Islamic law is the non-permissibility of inheritance between the Muslim and non-Muslim, which is also the case in the Arab laws, including the laws of countries that define the sectarian diversity of personal status; as in Egyptian law through Article VI of Law No. 77 of 1943 On the inheritance of non-succession between the Muslim and non-Muslim, which was followed by the Lebanese law of June 23, 1959, but if we return to the Algerian law, we find that he did not establish a base of attribution on this issue, and in the absence of a …


Extraterritoriality And Conflict Of Laws, Anthony J. Colangelo Jan 2022

Extraterritoriality And Conflict Of Laws, Anthony J. Colangelo

Faculty Journal Articles and Book Chapters

This Article views the modern federal presumption against the extraterritoriality of U.S. law through the lens of conflict of laws. It argues that the presumption makes many of the same mistakes that conflict methodologies have already made, and sometimes the mistakes are worse. It then proposes a way to harmonize federal extraterritoriality and state choice of law to identify a superior approach to both.