Need lawyer advice on international divorce laws

My question is specific to property division laws in a California
divorce when they conflict with the mariage contract original laws.

I got married in Quebec, Canada.  My wife and I signed a notorized
contract which state that we are choosing the Quebec matrimonial
regime of seperation as to property (in Quebec, all couple fall under
the regime of seperation or community property, we can only choose one
or the other).  Our wedding contract does not include anything else. 
No clause are included on its application out of state.

By Quebec laws, under this regime all ownership is seperate with the
exception of the family patrominy which includes family house &
furniture, family car, retirement&pension.

My understanding is that California law do honor out of state marriage
contract, but what about the quebec exception on seperate property,
family patrimony...

I bought a house and car while in California, bought it with my own
money, can prove that I use my own money for the down payment and
mortgage payment and both car and house have only my name on the
title....

Is the house and car seperate or community property?  The California
laws are conflicting with the Quebec marriage contract laws

mae98-ga 

     The disclaimer at the bottom of the page says:	

Important Disclaimer: Answers and comments provided on Google Answers
are general information, and are not intended to substitute for
informed professional .. legal ... or other professional advice.

 Consequently, I interpret the question
"Need lawyer advice on international divorce laws "

as asking for recommendation of a specialised legal firm which would
be competent to advise you. With that as a goal I have done a search
of information posted on this topic on the internet and found this article
which answers that question (specialised firm):


COMING TO AMERICA . . . WHAT IT MEANS FOR YOUR ESTATE 
PLAN AND YOUR MARITAL PROPERTY RIGHT

 For example, the executive who migrates from 
London to Los Angeles and acquires domicile in the State of California
for probate law purposes will have the entirety of his separate
property interests in properties that are attributable to the product
of labors performed during the marriage converted to quasi-community
property in which a surviving spouse would have an undivided 50%
interest in the event of death (or divorce). Elective share and
quasi-community rules ....

Law Offices of Christopher S. Armstrong
  Website: www.rmstrnglaw.com

http://www.rmstrnglaw.com/publications/Coming%20to%20America%20%20IBC%20Oct%202003%20Conference.pdf.

For more simple questions - what the CA rules say, e.g. on the question:

Is the house and car seperate or community property?

 answers can be found in the excellent NOLO books:
 http://www.nolotech.com/CA/CA.html

Even these (simple) questions can be complicated: 
example:
Car(s) and houses are community property 
- unless there is a valid prenuptial agreement. Even then the notion
of 'bought it with my own money' is questionable, unless your
prenuptial is recognized and you kept seperate finnances while in
California.
  Normally, money earned by either party and any property aquired
during the marriage is community property.

The type of property and public interest can influence the decision.

So, you both defintly need an advice of a lawyer, but it is also true
that if you two can agree on a settlement, possibly after a consultation
with an expert, you will both be better off. 

see also:

 A GRANT DEED (for the house)  was notorized to me as a
 'single man, - married man - separate property - ..???
http://answers.google.com/answers/threadview?id=433051



http://answers.google.com/answers/threadview?id=745451

http://answers.google.com/answers/threadview?id=237420
http://answers.google.com/answers/threadview?id=65619


Hedgie