Andrew has put his finger on an important distinction between property law and the PIL/conflict issues involved.
In my view, he is quite right, there is no point in pushing PIL/conflict considerations where there is no issue involved to be resolved. However that may not help the Texan lawyer in his jurisdiction which might attempt to classify or reclassify the issue differently.
I would amplify that this is personalty, and therefore the issue of an implied trust under s.36 LPA 1925 as to estates in land is not relevant.
The US tax viewpoint joint ownership in a succession duty context, is a separate issue resolved in theory at least by an overriding Federal IRS Regulation.
I stress here that the issue is important, as attempts at PIL overwriting such as the Succession Regulation-- not effective in these islands - will also be blocked by this classification as an issue of the law of property, not of succession.
Again, the shared civilian/common law concept of accession, as opposed to succession, as evidenced in Anglo-latinate terms by the concept of ius accrescendi can resolve issues reasonably clearly if one starts from the law itself s opposed to rewriting it through PIL spectacles.
The use of personal issues such as residence, nationality or domicile does not in principle alter the property laws applicable: an issue that Regulation 650/2012 had immense difficulty in addressing, and will struggle with for years to come.
Peter Harris