Re-imagining the Trust: Trusts in Civil Law

Re-imagining the Trust: Trusts in Civil Law

by Lionel Smith
     
 

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Although the trust is generally seen as a creation of the common law tradition, modern civilian systems are increasingly interested in incorporating the trust institution. This collection of essays explores multiple civilian experiences with the trust. The reform of Quebec's trust institution attracted worldwide attention in 1994. Louisiana's 1964 Trust Code stands in

Overview

Although the trust is generally seen as a creation of the common law tradition, modern civilian systems are increasingly interested in incorporating the trust institution. This collection of essays explores multiple civilian experiences with the trust. The reform of Quebec's trust institution attracted worldwide attention in 1994. Louisiana's 1964 Trust Code stands in an uneasy relationship with its general law of property. Israel has had a fascinating pluralist experience of multiples trusts. The People's Republic of China passed a Trust Law in 2001 and the development of the trust in this important economy is a matter of great interest and some controversy. France adopted a trust in 2007, and in Italy, trusts can be created through the choice of foreign governing law, under the Hague Trusts Convention. The concluding chapter draws conclusions from all the essays and sets out challenges for future research in the comparative law of trusts.

Product Details

ISBN-13:
9781107011328
Publisher:
Cambridge University Press
Publication date:
03/01/2012
Pages:
292
Product dimensions:
5.43(w) x 8.50(h) x 0.67(d)

Meet the Author

Lionel Smith is James McGill Professor of Law and Director of the Quebec Research Centre of Private and Comparative Law at the Faculty of Law, McGill University.

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