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Cardozo Journal of International and Comparative Law

Abstract

The article explores the challenges and successes in harmonizing family law, particularly matrimonial property regimes, within the European Union (EU) and the United States. It highlights how federalism in the U.S. leads to diverse state laws, while the EU has made strides through mutual recognition and procedural harmonization. The EU's approach, involving commissions and expert representation, offers a model for overcoming cultural and legal differences, demonstrating that harmonization is both feasible and beneficial for addressing the complexities faced by international couples.

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Law

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