The presentation will compare and contrast the common law (primarily as exemplified by New York law) and the civil law (primarily as exemplified by French law) approaches to the administration of decedents’ estates. The topics that will be addressed will include (1) who has title to the assets of a deceased person during the pendency of an estate or succession? (2) what is the role of a testamentary executor? (3) how is a decedent’s Will established or recognized as the decedent’s valid Will? (4) who is responsible for the liabilities of a decedent? (5) what are some major tax deadlines and considerations?, and (5) how does one determine the law that applies to the succession or estate of a decedent? In connection with the last question, there will be the a discussion of the major importance of the European Succession Regulation for U.S. citizens owning property or residing in Europe.

Michael W. Galligan is a Partner in the New York City law firm of Phillips Nizer LLP, where he practices in the field of trusts and estates, tax and immigration, with a special concentration in cross-border estates, trusts and estate planning and private international law. He is a member of the International Academy of Estates and Trusts and the American College of Estate Administration. He served as Chair of the International Section of the New York State Bar Association from 2009 to 2010 and became the first Chair of the NYSBA International Section to be elected thereafter to serve as a member of the Executive Committee of the New York State Bar Association. He lectures widely and has written many articles on topics related to international estate planning and choice of law as well as on the place of New York law in the “competition” for choice of law in private transactions and legal relationships.