Description

This book compares trust and patrimony laws in England, Scotland, Quebec and the Netherlands. The volume explores the multiple ways in which 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. 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; It focuses on the private law of England, Scotland, Quebec and the Netherlands and includes both new and important previously published papers written by distinguished comparative law scholars.

Trusts and Patrimonies

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Hardback by Remus Valsan

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This book compares trust and patrimony laws in England, Scotland, Quebec and the Netherlands. The volume explores the multiple ways... Read more

    Publisher: Edinburgh University Press
    Publication Date: 30/06/2015
    ISBN13: 9780748697748, 978-0748697748
    ISBN10: 0748697748

    Number of Pages: 320

    Non Fiction , Law , Education

    Description

    This book compares trust and patrimony laws in England, Scotland, Quebec and the Netherlands. The volume explores the multiple ways in which 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. 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; It focuses on the private law of England, Scotland, Quebec and the Netherlands and includes both new and important previously published papers written by distinguished comparative law scholars.

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