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-command economic system in the Soviet Union, and still predominate in Russia today. Keywords common law, common-law trust, corruption, economic ownership, equity, operative management, privatization, state enterprises, trust management 1. Trust Management and Similar Models in International Jurisprudence 1.1. A
A Comparative Study of Islamic Waqfs and English Trusts
Using a combination of the comparative legal method and hermeneutics, this book reconciles Islamic law with English trust’s law in these two main areas. It does not find it necessary for one legal system to reign supreme over the other, as such solutions will be questioned by the internal subjects of the dominated legal system, undermining the efficacy of this study. Rather, reconciliation is a mutual step to congruence taken by both legal systems. In the area of perpetuities, the book finds that neither Islamic
Waqfs must be perpetual, nor common law trusts must have a rule against perpetuities. Regarding ownership theories, the multiplicity of rendered theories in both legal systems presents more than one avenue of reconciliation. Overall, the study finds that private
Waqfs and private trusts can be reconciled without undermining the internal hermeneutic standpoints of both legal systems.
A Comparative Study of Islamic Waqfs and English Trusts
Using a combination of the comparative legal method and hermeneutics, this book reconciles Islamic law with English trust’s law in these two main areas. It does not find it necessary for one legal system to reign supreme over the other, as such solutions will be questioned by the internal subjects of the dominated legal system, undermining the efficacy of this study. Rather, reconciliation is a mutual step to congruence taken by both legal systems. In the area of perpetuities, the book finds that neither Islamic
Waqfs must be perpetual, nor common law trusts must have a rule against perpetuities. Regarding ownership theories, the multiplicity of rendered theories in both legal systems presents more than one avenue of reconciliation. Overall, the study finds that private
Waqfs and private trusts can be reconciled without undermining the internal hermeneutic standpoints of both legal systems.
Russian law does not currently contain the Anglo-American concept of a legal trust. However, Chapter 53 of the Civil Code establishes the concept of “fiduciary management of estate,” which some commentators have related to the common law trust and other trust-like devices.
Collected Courses of the Hague Academy of International Law Volume: 252 Brill | Nijhoff, Leiden | Boston, 1995, Abstract In his course dedicated to common law trust and trust in the Roman-Germanic tradition, Donovan Waters, Professor at the University of Victoria, Canada, elaborates on the theory
Trusts and on Their Recognition pp. 435 G. The move of civil law Japan to common law trust estate planning. pp. 444 H. So what is a trust ? pp. 447
. Hrsg. Ivo Elkuch [et al.], Mauren, Liechtenstein, GMG Juris Verlag, 1994. Trust in Liechtenstein law: comparison with its prototype, the Common law trust. K. Biedermann. Translated by H.G. Crossland, Oxford, Alvescot Press, 1984.
W. M. Waters, Donovan, Keywords: Trusts |, Mots clefs: Trustees |, In his course dedicated to common law trust and trust in the Roman-Germanic tradition, Donovan Waters, Professor at the University of Victoria, Canada, elaborates on the theory that, though the English trust and fideicommissum have
Secondary Sources Michele Graziadei, “Recognition of Common Law Trusts in Civil Law Jurisdiction under the Hague Trusts Convention with Particular regard to the Italian Experience,” in Re-imagining the Trust: Trusts in Civil Law (Cambridge University Press, 2012). Carlo Pavesio, "Italy," in