This 2001 book is an attempt to deal with trusts on a comparative law basis. It covers three models of trust: the English, the international and the civilian. It 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.
| ISBN: | 9780521623292 |
| Publication date: | 19th February 2001 |
| Author: | Maurizio Università degli Studi di Genova Lupoi |
| Publisher: | Cambridge University Press |
| Format: | Hardback |
| Pagination: | 432 pages |
| Series: | Cambridge Studies in International and Comparative Law |
| Genres: |
Comparative law Law: equity and trusts, foundations |