Abstract
IN THE CIVIL LAW THERE IS NO LEGAL INSTITUTION that directly corresponds to the common law trust.' Thus, not only is it impossible to create trusts under the civil law, but initially it also appears uncertain how the civil law should treat assets which are found within its domain and belong to an English or an American trust. It is the purpose of the present article to answer the latter question. Thus, suppose the following cases: Property belonging to a New York trust comes to Switzerland; can the creditors of the trustee seize it? Movable and immovable property situated in Switzerland is to be acquired for this trust; how is this to be accomplished? The following first section sets forth those aspects of trusts which are regarded as essential for legal comparison and on which the three subsequent sections are based. I
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