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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&rs

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