22/10/2026
One family. Five jurisdictions. Five very different outcomes.
At the 21st National Family Law Conference, the International Academy of Family Lawyers (IAFL) compared how New Zealand, England and Wales, Hong Kong, Singapore and California deal with property when a marriage ends across borders. Thank you to Suzanne Todd, Isaac Hikaka, Derek Ho, Shu Mei Hoon and Steven Yoda for sharing their insights.
The differences are striking. Some courts look at assets worldwide, while others leave foreign land out of the pool altogether. Some start from equal sharing, while others keep pre-marriage assets and inheritances separate. Even the time you must wait before filing ranges from months to years.
For separating couples with assets or family ties in more than one country, where proceedings start can affect what is divided and how.
If you are advising a client in this situation, our team is happy to talk through the cross-border issues early.