Next, it should be made clear that a reference to a foreign system of "law" is a reference to its rules of substantive law only. This may be supported by the argument that an initial reference to a foreign system of law should, in effect, be conclusive on the choice of law question. Following a policy decision to deviate from the normal procedure of applying the substantive lex fori, there should be a reference only to the foreign substantive law. If this view is not acceptable, and a further, or secondary, characterization accord- ing to foreign choice of law rules is deemed desirable, guidelines may still be established to avoid the problems of the renvoi doctrine. First, the circumstances under which secondary characterization may occur should be identified. Second, in those cases where there is a conflict of choice of law rules (as in our earlier domicile - nationality example), the forum's choice of law rule should be preferred, not through an application of the renvoi, but as a matter of policy. Another mode of establishing a degree of certainty in the ultimate decision of the court is through the use of statutes. An example of this is the British statute commonly known as Lord Kingsdown's Act.31 Although this statute permits the application of either forum or foreign law, it is helpful as an expression of forum policy. Unfor- tunately, in many instances when the legislatures have attempted to control the choice of law, the phraseology of the statute has been poor, and the statutes have led to confusion and distorting re-inter- pretation by the courts 2 Further, as Leflar points out, "socio- economic standards can change faster than disinterested legislators can repeal old and 'minor' legislation." 33 On a broader scope, codification at the international level may produce a degree of uniformity at both the national and international level. If we can assume that all legal systems are prima facie equally fair and reasonable, then international uniformity will not neces- sarily improve the law in any one country. 4 However, there may well be some positive value in creating uniformity at the interna- tional level with regard to matters such as title and status. It is certainly desirable that a potential series of actions to settle an estate be avoided, and that possible "limping" situations respecting