A discussion of the matrimonial regime that exists in Civil Law countries (France & Mexico, for this presentation), how they divide property upon divorce, what is compensatory allowance (which – in France - is largely based on the equitable factors that apply in equitable property states), and how a judge will look at the equitable property and community property principles of the United States. This will be compared with a discussion of the equitable distribution principle under UK law, the differences between the United Kingdom and the United States, and how a UK judge will look at the equitable property and community property principles of the United States.