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This document discusses the differences between how common law and civil law jurisdictions treat trusts. In civil law jurisdictions, trusts are viewed with suspicion and misunderstanding because they do not conform to the civil law principle of absolute title to property. The document explores possible ways to reconcile civil law and common law approaches to trusts, such as through the Hague Convention, using forced heirship rules, addressing control and sham issues, and employing a civil law structure like

Author

wemoji9738

Language

EN