海峡两岸法定继承制度比较研究

法定继承是大陆和台湾继承法律制度的重要内容。海峡两岸由于政治、经济、文化等条件的差异 ,关于法定继承的规定有诸多不同。台湾的立法详细具体 ,受德、日法系的影响较深 ,大陆的立法原则、简略 ,与大陆实际结合得较为紧密。了解海峡两岸法定继承制度的差异 ,不仅有助于继承立法的相互借鉴与完善 ,同时对正确处理两岸间的互涉继承关系有着非常重要的意义。

Comparing the Legal Systems of Inheritance in Mainland China and Taiwan

Legal inheritance is an important part of the inheritance legal systems in Mainland China and Taiwan. Yet due to the differences in politics, economy and culture, the two systems are quite different. Compared with the brief legislative principles in Mainland China, which are closely connected with the reality, the regulations in Taiwan are greatly influenced by the legal systems in Germany and Japan, very concrete. Therefore, understanding of these differences can help the two parts to get reference from each other and improve their legislation; it is also of great significance to proper handle with the mutual inheritance problems across the straits.