Although the trust is generally seen as a creation of the common law
tradition, modern civilian systems are increasingly interested in
incorporating the trust institution. This collection of essays
explores multiple civilian experiences with the trust. The creative
reform of Quebec’s trust institution in 1994 has attracted worldwide
attention. In Louisiana, the 1964 Trust Code stands in an uneasy
relationship with the general law of property. Israel has had a
fascinating pluralist experience of multiple trusts. The People’s
Republic of China passed a Trust Law in 2001 and the development
of the trust in this important economy is a matter of great interest
and some controversy. France adopted a trust in 2007, and in Italy
trusts can be created through the choice of foreign governing law,
under the Hague Trusts Convention. The concluding chapter draws
conclusions from all the essays, and sets out challenges for future
research in the comparative law of trusts.