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Renvoi

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The process by which a court adopts the rules of a foreign jurisdiction with respect to any conflict of laws that arises.

In some instances, the rules of the foreign state might refer the court back to the law of the forum where the case is being heard.

The term renvoi also refers to the rules that, in a lawsuit by a nonresident upon a cause arising locally, the capacity to sue is determined by the law of the nonresident's domicile, rather than by local law.

The doctrine of renvoi is seldom followed in the United States and has also been rejected by a number of foreign legal scholars.



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Subject to a contrary intention, the normal definitional renvoi to domestic law under Article 3(2) of a typical OECD-styled treaty should produce the same effects under a treaty.
 
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