Under an antenuptial agreement executed in Quebec, P made D the beneficiary of a $125,000 trust fund. Later, in consideration for renouncing her interest in this trust fund, D was made the beneficiary of a $1,000,000 trust, under an instrument executed in Quebec at the settlor's domicil, but with a New York trustee, the trust to be administered in New York where a substantial portion of the res was located at the time of settlement. Under the local law of Quebec such modification of the antenuptial agreement was invalid; under the local law of New York it was valid. When P sued in New York to revoke the trust, it was held that the local New York law was applicable. Hutchison v. Ross, (N. Y. 1933) 187 N. E. 65.
CONFLICT OF LAWS - INTER VIVOS TRUST-ADMINISTRATION IN STATE OTHER THAN STATE WHERE CREATED,
Mich. L. Rev.
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