November 01, 2020 Feature

International Prenups: A World View

Peter M. Walzer

We don’t know whether Meghan Markle and Prince Harry entered into a prenup, but if they had, their lawyers would have to wrestle with many difficult issues. Would English law apply to the prenup? What if they chose to live in another country? At the time of the “marriage of the century,” this seemed farfetched. Now it is a reality. Meghan and Harry first moved to British Columbia and then moved to California. If you were the lawyer that drafted the prenup of the century, would you have anticipated all these moves? Perhaps this article will help you navigate the dangerous waters of multijurisdictional agreements the next time you represent royalty—or anyone else who may be moving to another state or country after they marry.

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