estate planning news  trends

Michael McAuley examines the current treatment of trust concepts in non-U.S. jurisdictions

The Worlds of the Trust

There’s no one best approach for all jurisdictions


In the universe of the trust, there are several different worlds. There’s the civil law world and the common law world. There are also legal systems with mixtures of common and civil law ideas. Neither the common nor the civil law world is entirely clear-cut, though, and subdivisions abound. After examining some very different approaches, I&

All access premium subscription

Your subscription will include 12 months of Trusts & Estates magazine and access to premium content on

Hide comments


  • Allowed HTML tags: <em> <strong> <blockquote> <br> <p>

Plain text

  • No HTML tags allowed.
  • Web page addresses and e-mail addresses turn into links automatically.
  • Lines and paragraphs break automatically.