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The monograph contains a comprehensive study of trust ownership existing in common law countries, as well as a detailed analysis of various types of trusts and trust-like structures operating in civil law and mixed legal systems, in particular in France, Italy, Germany, Switzerland, South Africa, Japan, China and other countries.
Particular attention is paid to the qualification of a trust by the courts of countries that have not traditionally recognised trust ownership. Based on a comparative analysis of the provisions of the legislation of different countries and the practice of its application, the author examines global trends in the recognition and incorporation of trust into the law of countries that have long denied this institution. The author reveals the peculiarities of trust-like structures in Ukraine and the prospects for introducing the trust institute into domestic law.
The book is intended for lawyers, scholars, practitioners, teachers, students and persons interested in current trends in the field of property management.