ægtepagt

English translation: nuptial agreement

GLOSSARY ENTRY (DERIVED FROM QUESTION BELOW)
Danish term or phrase:ægtepagt
English translation:nuptial agreement
Entered by: WordLogic

20:02 Jul 1, 2013
Danish to English translations [PRO]
Law/Patents - Law (general) / Ægtepagt
Danish term or phrase: ægtepagt
Er i tvivl om den korrekte engelske ækvivalent for en ægtepagt (om særeje), som går umiddelbart forud for et ægteskabs indgåelse, da denne tegnes udelukkende i anledning af det forestående ægteskab. Bruges marital/marriage agreement udelukkende hvis pagten tegnes efter ægteskabets indgåelse, eller kan den bruges her på samme måde som eks. prenuptial agreement?

Hvad siger I derude? :)
WordLogic
Denmark
Local time: 07:47
antenuptial settlement
Explanation:
antenuptial settlement

If the agreement is drawn up and signed before the marriage is entered into.

There are nuptial agreements - and the term covers pre- or antenuptial agreements AND post-nuptial agreements.

Here you need to be careful about using English equivalents - you are presumably translating an agreement made under Danish law, to which Danish law will apply.

I have just been reading an interesting article on nuptial agreements, and the provisions of English law are not always the same as the provisions of other jurisdictions.

Sometimes you have to use the terminology that indicates what is meant in Danish law, not the terminology that would be used in the equivalent situation in English or American law.

I believe generally Danish law recognises prenuptial agreements far more straightforwardly then English law - but I have not read enough to be certain,and it varies from case to case and couple to couple. Americal law may vary from state to state - I do not translate law for US clients.
(In other words, I am a translator, not a lawyer...)

http://www.atlanticchambers.co.uk/File/MARITAL PROPERTY AGRE...
Selected response from:

Christine Andersen
Denmark
Local time: 07:47
Grading comment
Thank you for your thorugh reply. I went for the more neutral "nuptial agreement" to avoid distinguishing between pre- and post- ones as this is not commonly done in Danish law.
4 KudoZ points were awarded for this answer



Summary of answers provided
4Marriage contract providing for separation of property
Pernille Kienle
5 -1postnuptial agreement
Helen Johnson
4marital property agreement; premarital and marital agreement; nuptial agreements.
Elenice Brasseland
4Antenuptial agreement or prenuptial agreement
Hans Wang
3pre- or post nuptial settlement severing the joint tenancy
Adrian MM. (X)
3antenuptial settlement
Christine Andersen


  

Answers


16 mins   confidence: Answerer confidence 4/5Answerer confidence 4/5
Marriage contract providing for separation of property


Explanation:
Iflg. Gyldendals juridiske ordbog, hedder det 'marriage contract providing for separation of property' netop i forbindelse med ægtepagt om SÆREJE. Håber, du kan bruge det! (evt. marital agreement i stedet for marriage contract, hvis det er US-engelsk - og evt. division of property).

Pernille Kienle
Canada
Local time: 23:47
Meets criteria
Specializes in field
Native speaker of: Native in DanishDanish, Native in EnglishEnglish
PRO pts in category: 24
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29 mins   confidence: Answerer confidence 3/5Answerer confidence 3/5
pre- or post nuptial settlement severing the joint tenancy


Explanation:
thereby splitting community into separate property.

There can be a pre- or post-nup - which might be better to spell out for the Danaish term if covers both.


--------------------------------------------------
Note added at 30 mins (2013-07-01 20:32:42 GMT)
--------------------------------------------------

(ante- or) post-nuptial

Example sentence(s):
  • En ægtepagt er en aftale mellem ægtefællerne om den formueordning, der skal være gældende for ægteskabet. da.wikipedia.org/wiki/Ægtepagt ‎
Adrian MM. (X)
Local time: 07:47
Does not meet criteria
Specializes in field
Native speaker of: Native in EnglishEnglish
PRO pts in category: 113
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1 hr   confidence: Answerer confidence 3/5Answerer confidence 3/5
antenuptial settlement


Explanation:
antenuptial settlement

If the agreement is drawn up and signed before the marriage is entered into.

There are nuptial agreements - and the term covers pre- or antenuptial agreements AND post-nuptial agreements.

Here you need to be careful about using English equivalents - you are presumably translating an agreement made under Danish law, to which Danish law will apply.

I have just been reading an interesting article on nuptial agreements, and the provisions of English law are not always the same as the provisions of other jurisdictions.

Sometimes you have to use the terminology that indicates what is meant in Danish law, not the terminology that would be used in the equivalent situation in English or American law.

I believe generally Danish law recognises prenuptial agreements far more straightforwardly then English law - but I have not read enough to be certain,and it varies from case to case and couple to couple. Americal law may vary from state to state - I do not translate law for US clients.
(In other words, I am a translator, not a lawyer...)

http://www.atlanticchambers.co.uk/File/MARITAL PROPERTY AGRE...

Christine Andersen
Denmark
Local time: 07:47
Meets criteria
Specializes in field
Native speaker of: Native in EnglishEnglish
PRO pts in category: 175
Grading comment
Thank you for your thorugh reply. I went for the more neutral "nuptial agreement" to avoid distinguishing between pre- and post- ones as this is not commonly done in Danish law.
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13 hrs   confidence: Answerer confidence 5/5 peer agreement (net): -1
postnuptial agreement


Explanation:
Saw this a few times on Google, including in Wikipedia.

Helen Johnson
United Kingdom
Local time: 06:47
Meets criteria
Specializes in field
Native speaker of: Native in EnglishEnglish
PRO pts in category: 4

Peer comments on this answer (and responses from the answerer)
disagree  Elenice Brasseland: Google alone can't give the right answer. There are different types of "postnuptial agreements".
2 hrs
  -> Obviously not, but it provides contexts that you can open up to read
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11 hrs   confidence: Answerer confidence 4/5Answerer confidence 4/5
marital property agreement; premarital and marital agreement; nuptial agreements.


Explanation:
Since you mention 'ægtepagt (om særeje), efter indgåelsen af ægtesgabet', you may try 'postmarital/postnuptial agreement (separate property)' and see how it works on your text/context.

I guess **separate property** can only be determined through **the spouses’ marriage contract** => **Marital Property Agreement**

Useful link on the subject: http://lawcommission.justice.gov.uk/docs/cp198_Marital_Prope...

Good luck!
"Loved children have many names." :)



--------------------------------------------------
Note added at 16 hrs (2013-07-02 13:01:23 GMT)
--------------------------------------------------

Your questions are about finding English equivalents. As I said, *loved children have many names* ;)

ægtepagt => marital agreement; marital/marriage contract

ægtepagt (om særeje) => marital agreement (separate property); marital property agreement;

ægtepagt (om særeje) som tegnes efter ægteskabets indgåelse => postmarital/postnuptial agreement (separate property) OR postnuptial property agreement...

That could go on and on...
Christine is so right: we need to be careful about using English equivalents!

I must stop now... Good luck!

just one more link:
http://www.uslegalforms.com/fl/FL-01713-AZ.htm
This Postnuptial Property Agreement is made with the intent to define and specify the respective and collective rights of the parties in the separate and joint property of the parties. The parties acknowledge that they were represented by counsel during the negotiations of the agreement and the legal consequences of the agreement have been fully explained. This agreement must be notarized and witnessed.


Example sentence(s):
  • On July 18, 2012, the Commissioners approved the Uniform Premarital and Marital Agreements Act (UPMAA), which replaces the Uniform Premarital Agreements Act (UPAA), approved in 1983.
  • a marital agreement may be made excluding or modifying the community.

    Reference: http://www.msba.org/departments/commpubl/publications/bar_bu...
    Reference: http://www.familylawweek.co.uk/site.aspx?i=ed70850
Elenice Brasseland
Local time: 07:47
Does not meet criteria
Specializes in field
Native speaker of: Portuguese
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23 hrs   confidence: Answerer confidence 4/5Answerer confidence 4/5
Antenuptial agreement or prenuptial agreement


Explanation:
Agreement entered into prior to marriage. The agreement modifies how property is distributed after the marriage ends. Whether the agreement is valid depends the laws of location where the agreement is entered into and/or the laws of the location where enforcement is sought. In the location where I practice law, a clause in a prenuptial agreement dealing with child custody or child support is invalid no matter how the agreement is worded.


    Reference: http://en.wikipedia.org/wiki/Prenuptial_agreement
Hans Wang
Local time: 01:47
Meets criteria
Works in field
Native speaker of: Native in EnglishEnglish, Native in NorwegianNorwegian
PRO pts in category: 8
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