Prenup drafted in Germany valid in Canada?
Hi All!
Me and my partner are getting married in November and I have a question around international prenups.
I'm originally from Germany and have dual citizenship while my partner is a US citizen and has PR here in Canada. We're planning to do a prenup since I'm self-employed and own part of a family business in Germany that requires asset separation as a stipulation of me owning shares.
My parents are willing to pay for a lawyer to draw up the prenup in Germany. It would be in German (obviously) and I don't think any of the lawyers in my small hometown has the knowledge in the English language or Canadian law to make sure it alines completely with rules over here or would be able to translate it to a professional degree. But I'd love to avoid having to pay for a separate lawyer here if possible.
Does anyone here have any experience with this kind of situation? Is there anything we should particularly be aware of? Would it make sense to have my parents' lawyer in Germany draw up the prenup and then potentially run it by a lawyer who is familiar with German and Canadian family law (if someone like that exists, not even sure how to find that to be honest)?
Any advice would be greatly appreciated. Thank you!