Federalism and conflict of laws solution system: comparative study on conflict of laws solution system of United States of America and the European Union

On the basis of constitution and social and cultural contexts, each country has its own private international law system. Communication growth, as well as social and economic interchanges on the international scene, inescapably, may cause conflict of laws. Concerning countries with federal system like, United States of America, conflict of laws not only may occur between laws of the United States and law of the other countries, but also in a distinctive manner, among states of the USA together. European Union is in the same situation. Although, the convention of states in Europe does not frame a federal system, but it has some federal characteristics, in some respects. , considering the premise that the creation idea of the European union has been inspired by federalism principles, The purpose of this contribution is, with a descriptive and analytic- comparative manner, to explore the interstate and member states traits of conflict of laws solution systems in USA and EU in order to, answer the question that what are the differences and resemblances of EU member states conflict of laws solution system and the systems of federal countries. Finally, this paper, conclude the European Union has unique characteristics which differentiate its conflict of laws solution system from federal systems.