Presently, inheritance law differs based on matrimonial regimes, of which there are four.

The country governing the matrimonial regime (for spouses or former spouses only)

However, common law partners do not have any legal rights between them, such as alimony, family patrimony, compensatory allowance and matrimonial regime.

Also traditional rules dictating matrimonial regimes and inheritances may be applied only with the consent of the parties concerned, or else by default the national law is used.

Many countries, including Canada, France, Italy, and Germany, have matrimonial regimes, in addition to, or some cases, in lieu of prenuptial agreements.

In Common law countries, the default and only matrimonial regime is separation of property, though some U.S. states, known as community property states, are an exception.

For him, the "father" of the institution of caste could be the Brahmins who adopted a strictly endogamous matrimonial regime, leading the other groups to do the same in order to emulate this self-proclaimed elite.

In case of divorce, the rules for administering the Divorce Act were retained using Quebec's old community property matrimonial regime until 1980, when new legislation brought an automatic equal division of certain basic family assets between spouses.

Matrimonial regimes are applied either by operation of law or by way of prenuptial agreement in Civil law countries, and depend on the lex domicilii of the spouses at the time of or immediately following the wedding.

Article 171 specifically states that the usual financial aspects of a marriage, such as liquidation of matrimonial regime or the granting of intestate inheritance (meaning the laws governing inheritances of people whose spouses die without a will) do not apply.

Civil-law and bijuridical jurisdictions, including Quebec, Louisiana, France, South Africa, Italy, Germany, Switzerland, and many others, have statutory default matrimonial regimes, in addition to or, in some cases, in lieu of regimes that can only be contracted by prenuptial agreements.

Matrimonial regimes, or marital property systems, are systems of property ownership between spouses providing for the creation or absence of a marital estate, and if created, what properties are included in that estate, how and by whom it is managed, and how it will be divided and inherited at the end of the marriage.