Conflicts Keyed to Currie
In re Schneider’s Estate
Schneider was born in Switzerland but had become a naturalized American citizen of the United States. He was domiciled in New York and died there. He left a will disposing of all of his assets. A portion of his assets disposed of by the will consisted of real property located in Switzerland, which he kept ownership of following his move to the United States. Internal Swiss law specified that certain portions of a decedent’s property must descend to his legitimate heirs and that any testamentary disposition contrary to this law was void. The will was probated in New York. At the time of probate, the administratrix of the estate had liquidated the real property in Switzerland and had brought the resulting funds into New York. A claim was filed against the estate by the decedent’s heirs in Switzerland claiming the right to the proceeds as determined by Swiss law. The testamentary disposition was valid under New York law.
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