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This piece is a short discussion on the English; and more widely the common law concept of the trust and its traditional exclusion from civil law systems.  It seeks to unearth that the apparent distaste civil law systems have for the common law trust is rooted in each system’s respective attitude to rights in property and at least some degree of mistranslation.  This apparent gulf in understanding can be bridged by incorporating the trust into the more ancient Roman law concept of the patrimony, thereby making the trust sit more comfortably in civil law jurisdictions.  In bridging the divide, this new appreciation for the trust challenges us as common lawyers to reconsider the traditional common law premise of the trust as being less about proprietary interest as it is about personal rights and obligations.

CIVIL LAW JURISDICTIONS AND THE ENGLISH TRUST IDEA: LOST IN TRANSLATION?