Jurisdiction Comparison Grid

Purpose of the grid. This appendix collects in one place the comparisons made across Parts IV and V. Each grid restates propositions developed in a chapter, and each row names the paragraph where the authority is discussed. The grids add no new law. Where a chapter flagged a point for verification, the grid repeats the flag.

The seven dimensions. The grids follow the seven dimensions of the comparative method: substantive law, litigation barriers, courts and record, stability and standing, infrastructure, tax and reporting, and the reach of U.S. courts (see supra ¶ 2110.01). A jurisdiction's protective statute is only one of those dimensions, and the grids should be read with the weighting rules of chapter 21 in mind: for a client whose dominant threat is a tort creditor above insurance limits, the substantive law and the litigation barriers matter most; for a client whose dominant concern is a spouse, the treatment of marital claims and the divorce court's power over the client matter most (see supra ¶ 2110.02).

How to read the grids. The grids describe the law of each jurisdiction as applied by its own courts. They do not predict what a U.S. court will do with that law. For a U.S. resident, the decisive question is usually whether a home-state court will apply the chosen law and whether it can coerce the client (see supra ch. 35; app. A, ¶ A40). A grid entry of "not enforced" means that the jurisdiction's courts will not enforce a foreign judgment against trust property. It does not mean that the client is safe from contempt in the court that gave the judgment (see supra ch. 39).

Currency. The grids state the law as drafted in the chapters, through November 2026. Statutes in this field are amended often, and several jurisdictions renumber their codes on revision. The current text of every statute must be checked before a grid entry is relied upon.

The grids.