Banking scholars also argue that Islamic law blocked indigenous financial modernization in Muslim countries because of an inheritance system that restrained capital accumulation, inhibitions on pooling resources that discouraged investment diversification, and a traditional aversion to the concept of legal personhood for corporations, which hampered the development of financial entities.

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EU-wide criteria would make clear which country's legal system applies when an inheritance concerns more than one member state, a move designed to reduce costly legal disputes and cut red tape for heirs.

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In the United Kingdom and South Africa, due to the "necessity" of accommodating Muslims into the welfare system and succession and inheritance laws, polygamous Muslim marriages are now de facto recognized by the respective governments.

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"If Congress doesn't do anything for ten years, in the middle of 2011, people would be getting hit with inheritance taxes and Congress could pass retroactive legislation eliminating the estate tax to make the system more equitable, " Edwards says.

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"The Conservatives have made a series of uncosted tax promises - tax bribes, " said Mr Clegg, referring to Tory promises to recognise marriage in the tax system, limit the National Insurance rise, freeze council tax and raise the inheritance tax threshold.

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