Separate Property Systems
- separation of property - all property, pre-marital or marital, is owned separately. (Fr séparation de biens, Sp separación de bienes, Du scheiding van goederen, Ger Gütertrennung, It separazione dei beni)
- separation of property with equitable distribution - in instances of inequality between spouses, an underprivileged spouse may be awarded some of the dominant spouse's property by the courts.
- accrual system (aka differed community of property) - marital property is owned separately during the marriage, but after marriage (divorce, death of a spouse), the net assets are lumped together as property in joint tenancy and divided. (Fr participation aux acquêts, Sp participación, Du aanwasbedeling, Ger Zugewinngemeinschaft, It partecipazione agli acquisti)
Read more about this topic: Matrimonial Regime
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