By Lionel Smith
ISBN-10: 0521017769
ISBN-13: 9780521017763
ISBN-10: 1107011329
ISBN-13: 9781107011328
Even though the belief is mostly visible as a construction of the typical legislation culture, sleek civilian platforms are more and more attracted to incorporating the belief establishment. This choice of essays explores a number of civilian stories with the belief. The reform of Quebec's belief establishment attracted world wide consciousness in 1994. Louisiana's 1964 belief Code stands in an uneasy courting with its common legislations of estate. Israel has had a desirable pluralist event of multiples trusts. The People's Republic of China handed a belief legislations in 2001 and the improvement of the belief during this vital economic climate is an issue of serious curiosity and a few controversy. France followed a belief in 2007, and in Italy, trusts could be created throughout the collection of international governing legislation, less than the Hague Trusts conference. The concluding bankruptcy attracts conclusions from the entire essays and units out demanding situations for destiny study within the comparative legislations of trusts.
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Additional resources for Re-imagining the Trust: Trusts in Civil Law
Example text
Above, note 5, articles 1299–1370. 22 regarding the diversity of the trust administration of property or to secure a claim. The conception of the fiducie which takes up the model of the fiducia raises difficulties at two levels with respect to its legal ordering. First, the fiduciary arrangement presents itself under the complexion of a contract transferring property, accompanied by obligations which bind the acquirer. In accordance with the principle which limits the rights and obligations of a contractual relationship with the contract’s parties, the acquirer’s obligations cannot be set up against third parties who subsequently bring claims to bear against him or her.
Treggiari, Minister ultimae 51 michele graziadei of the historical accidents that have contributed to the making of the law of trusts in common law jurisdictions is a matter for debate, rather than a settled point. 53 To sum up, the definition in article 2 of the Convention embraces some institutions that share features that are often, but wrongly, considered to be peculiar to trusts governed by the common law. This does not mean, however, that every arrangement whereby a person holds property in one capacity or another for another person – for example, a deposit or a bailment, an agency or a mandate – is a trust for the purposes of the Convention.
Van Loon, ‘Report on Trusts and Analogue Institutions’, in Proceedings, above, note 8, vol. II, p. 10, provided a short overview of some of these institutions for the delegates at The Hague. Much comparative work has been done on this point since then, but this is not the place to review it. Articles 2011 ff. Code civil. Loi du 27 juillet 2003 (M´emorial A, no. 124 du 3 septembre 2003, p. 2619). ´ de la S. M. Santisteban, ‘Los trusts como instrumento de transmision riqueza familiar en el Derecho europeo continental’, in C.
Re-imagining the Trust: Trusts in Civil Law by Lionel Smith
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