The problem that confronts us in this chapter is how to determine what system of law regulates the rights of a husband and wife in the movable and immovable property which either of them may possess at the time of marriage or may acquire afterwards. Important consequences may ensue depending on which law is chosen. For instance, the result of choosing one particular legal system may be that the property of the wife passes entirely to the husband, as was substantially the case in England prior to 1883. Again, if an Englishwoman marries a Belgian and Belgian law is...
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