My Divorce Handbook
International Divorce​
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Some content is in French
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Is my marriage in a foreign country valid in the U.S.?
The below article uses Italy as an example. One of the last paragraphs indicates a general rule (with its exceptions): That a marriage abroad, if it doesn’t violate U.S. Law, is valid in the U.S., especially if the marriage certificate has an Apostille.
https://it.usembassy.gov/u-s-citizen-services/marriage/
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Divorce in two countries is double the trouble.
Article that provides a very high-level view of the complications around international divorce.
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The enforcement of Foreign Judgments in France under the Nouveau Code de Procedure Civile.
Lots of helpful information to understand what and how Exequatur actually works in France and in General. Note: When doing your divorce you need to be aware of certain conditions that need to be present for the divorce Decree to be valid abroad.
http://lawdigitalcommons.bc.edu/cgi/viewcontent.cgi?article=1579&context=iclr
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A Lawyer’s Handbook for Enforcing Foreign Judgments in the United States and Abroad.
This is a resource that you may provide to your counsel. Google provides a robust preview of the content.
https://books.google.com/books?id=4KQNkLiYc3sC
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Faire reconnaître un divorce prononcé à l’étranger.
Different from the Exequatur (which makes enforceable a court order regarding possession, assets, etc.), the « Vérification d’opposabilité » is the usual process to have France acknowledge the enforceability and validity of a divorce Decree in a country other than France.
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Cases Involving Foreign Nationals (requirements for enforcement and recognition in the United States of a judgment rendered abroad).
You will have in your hands a rather technical paper, part of an “Advanced Family Law Course.” That being said, Section IX is worth reading.
The document provides information about what Texas requires to recognize judgments from a foreign country.
http://www.texasbarcle.com/Materials/Events/9198/120827.pdf
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Le contract de marriage dans un context international.
How does it work if you are French? How does a prenuptial agreement outside of France works?
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https://www.notaires.fr/fr/lint%C3%A9r%C3%AAt-du-contrat-de-mariage-dans-un-contexte-international-0
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La Séparation / Le Divorce au Delà des Frontières.
If you got married in France, and want to file divorce in a different country, this is a good place to start.
http://www.notaires.paris-idf.fr/international/la-separation-le-divorce-au-dela-des-frontieres
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Divorce et Nationalité: Quel est le Tribunal Compètent? Quelle Loi s’appliquera à votre divorce?
A document that discusses choice of law and Jurisdiction.
https://www.village-justice.com/articles/DIVORCE-NATIONALITE-TRIBUNAL-COMPETENT,13818.html
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Divorce et résidence a l’étranger.
Some general pointers about divorcing in a foreign country (seen from the French point of view).
https://www.notaires.fr/fr/divorce-et-r%C3%A9sidence-%C3%A0-l%E2%80%99%C3%A9tranger
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Changement automatique du régime matrimonial.
As you read, in some situations you can go from having separation of assets to having common assets automatically. Caveat: This change is only applicable to those married after 1992. Those that have a prenuptial agreement are not subject to a change of regime based on their residence.
https://www.notaires.fr/fr/expatriation-eviter-la-mutabilit%C3%A9-automatique
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Français ou étrangers, la loi française peut vos permettre de divorcer.
A read that will be useful for those divorcing a French citizen.
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Divorce depuis l'étranger : les procédures à suivre pour les ressortissants français résidant hors de France.
The article highlights that French law gives French citizens a right to file divorce in France, for the sole fact of being French.
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Section V. of PDF - International Issues – Case when a prenuptial agreement signed abroad is applied in the United States.
As the title indicates, the article gives a glimpse on how a foreign prenuptial agreement is viewed in the United States.
https://www.iafl.com/cms_media/files/prenuptial_agreements_in_the_us.pdf
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Prenuptial Agreements: US Law, Thailand Law and EU Law Compared.
Useful for those trying to figure out what their prenuptial agreement entails.
http://www.thailawforum.com/articles/international-prenuptial.html
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Convention of 14 March 1978 on the Law Applicable to Matrimonial Property Regimes.
This read will be useful to identify risks and opportunities. Several countries are part of the Hague Conference.
https://www.hcch.net/en/instruments/conventions/full-text/?cid=87
Not all countries sign all the documents that the Convention generates. The below link shows a map of the countries that are part of the Convention.
https://www.hcch.net/en/states/hcch-members
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New York High court Upholds French Prenup.
Useful to get a glimpse of how the prenuptial battles take place.
https://cityroom.blogs.nytimes.com/2008/12/18/new-york-high-court-upholds-french-prenup/
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French Prenuptial Agreement Adopting "Separation of Estates” Regime Constituted Waiver of Equitable Distribution.
A rather long article, it gives a good idea of the “back and forths” that happen in court.
http://brandeslaw.blogspot.com/2008/12/french-prenuptial-agreement-adopting.html