Trusts in Mixed Legal Systems(2001)
This edited volume considers to what extent mixed legal systems, such as those of Scotland, South-Africa and Quebec, can offer an attractive model for an international variant of trust. Two recent developments have increased the need to reconcile the Anglo-American trust with principles of civil law. The first is the overall tendency of unifying or harmonizing areas of private law, and especially commercial law, and therefore also trust laws, not only in Europe but also elsewhere. The second is the entry into force of The Hague Convention on the Law Applicable to Trusts and on their Recognition, which makes questions regarding the effect of trusts recognized in a civil jurisdiction imminent.
- Mixed jurisdictions
Citation InformationJan M Smits and J. Michael MIlo. Trusts in Mixed Legal Systems. Nijmegen(2001)
Available at: http://works.bepress.com/jan_smits/89/