Does the U.S. Elder Law “Model” Work in Other Countries?

When I was at the International Elder Law Conference with a focus on Veterans Law in Honolulu, the World Study Group met the day before the conference started. There were several interesting presentations by academics on their latest research projects. One presentation lead to an interesting discussion of whether there is a U.S. elder law model, and what elder law means both within the U.S. and in other countries. It is an interesting thought—is elder law so unique that it is very country-specific, and not just because of substantive law or are there enough characteristics and commonalities (beyond the person’s age) so that elder law really is a practice area that knows no borders?

I like to use the cookie cutter analogy when trying to explain why things should not always look the same. Here’s the analogy-when making holiday cookies using a cookie cutter, the idea is uniformity-that the cookies in a certain shape all look the same. Here, perhaps elder law is not a cookie cutter practice area. So although many countries may have attorneys who practice elder law, what is elder law in the U.S. may not be the same as in Canada, or Japan, or Australia, for example. Is it the laws, culture and solutions that make it country-specific, or is it something else?

What do you think?