Trusts: A Comparative Study

ISBN-13: 9780521623292 / Angielski / Twarda / 2001 / 432 str.

Maurizio Lupoi; James Crawford; John Bell

Opis

This is the first attempt to deal with trusts on a comparative law basis. The book examines more than thirty countries, and submits a unified theory of trusts. The effects of the Hague Convention of 1985 are discussed, as well as its implementation in ratifying civil law countries, where it is now possible to form trusts under a foreign law. Academics will find this book a novel approach to the English-model trust, and practitioners will find it gives a wealth of information on foreign legal systems.

Spis treści

1. Introduction; 2. The heart of the trust; 3. The traditional English model; 4. The international trust model; 5. Trusts in civil law or mixed legal systems; 6. The Hague Convention; 7. Trusts in Italy.