Trusts and Patrimonies
This volume explores how the private law concepts of trust and patrimony interact in various jurisdictions, with a view to advancing the understanding of the trust as a fundamental legal concept.
It comprises new and previously published papers written by distinguished comparative law scholars. The authors investigate whether the common law trust could be understood as a civil law patrimony by appropriation, and whether civil law and mixed traditions could create local versions of the common law trust using patrimony as the main conceptual building block.
- The first comparative law book addressing the relation between trust and patrimony from a comparative and trans-systemic perspective
- Focusses on the private law of England, Scotland, Quebec and the Netherlands
- Responds to the increasing appeal and popularity of the institution of trust in civil law jurisdictions in Continental Europe and Asia
- An invaluable resource for legal researchers, practitioners and policy makers interested in the theoretical and practical challenges that the trust poses in civil law countries
|Publisher:||Edinburgh University Press|