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Article

Американские доктрины коллизионного права в кодификациях международного частного права Квебека и Луизианы

Вопросы правоведения. 2011. № 1. С. 159-182.
Морозова В. В.

The study dwells on the problem of interaction between North American legal doctrine and codifications of private international law in the state of Louisiana and the Province of Quebec. Covering both classical and modern USA schools of thought in the area of conflict of laws, the article also includes a comparative analysis of Book IV (Conflict of Laws) of Louisiana Civil Code and Book X (On private international law) of Quebec Civil Code respectfully. On comparing these acts, the authors dwell on a thesis that, in spite of the obvious similarities between respectful legal systems, one cannot state undoubtedly that American doctrine of private international law has been recepted by abovementioned codifications in equal measure. Therefore, despite all the similarities, the doctrinal traditions on which they are respectfully based are actually different.