Abstract

Abstract By comparing English, Mexican, and French trust law, it is possible to shed light on the successes and shortcomings of each jurisdiction and, by this, propose principles for an ideal regime of the express trust. The comparison starts by analyzing the personal elements of the express trust and continues with the study of its real elements. Proposing an ideal regime can be a theoretical basis for future reforms introducing or improving the trust in civil and common law jurisdictions.

Full Text
Paper version not known

Talk to us

Join us for a 30 min session where you can share your feedback and ask us any queries you have

Schedule a call

Disclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.