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.

This collection of essays by experts in the field explores the place of the trust in the modern civil law.

About 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.


Book Information
ISBN 9781107011328
Author Lionel Smith
Format Hardback
Page Count 292
Imprint Cambridge University Press
Publisher Cambridge University Press
Weight(grams) 510g
Dimensions(mm) 222mm * 143mm * 17mm