TY - JOUR
T1 - An Ideal Regime for the Express Trust A Comparative Analysis: English, French, and Mexican Law
AU - Ibarra Garza, Rafael
PY - 2020/5/11
Y1 - 2020/5/11
N2 - 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.
AB - 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.
UR - https://www.mendeley.com/catalogue/aeed3910-9a9d-3142-8ea0-89cc8df659a3/
U2 - https://doi.org/10.1093/tandt/ttaa018
DO - https://doi.org/10.1093/tandt/ttaa018
M3 - Article
SN - 1363-1780
VL - 26
SP - 336
EP - 346
JO - Trusts Trustees
JF - Trusts Trustees
IS - 4
ER -