The Trust : bridge or abyss between common and civil law jurisdictions?

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The Trust : bridge or abyss between common and civil law jurisdictions?

edited by Frans Sonneveldt, Harrie L. van Mens

Kluwer Law and Taxation, c1992

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内容説明

The Trust is a world-wide legal phenomenon which is used for a variety of purposes. Originally a common law concept, it has "invaded" a number of civil law jurisdictions. France, the continental law system par excellence, is about to introduce the trust within its jurisdictions. Most civil law jurisdictions, however, are most reluctant to follow France's example. In this respect, the Hague Convention on Trusts has solved a number of questions raised by the appearance of the trust in civil law jurisdictions. This book deals with the trust and its tax consequences in some common law countries, viz the UK and the USA, and in a number of civil law countries, Switzerland, the Netherlands, and France. An introductory chapter discusses the trust phenomenon as such, touching upon its historical background, the uses of trust, the modern day trust and also the Hague Convention on Trusts. The closing chapter is devoted to the treatment of trusts under the OECD Model Convention. In dealing with these subjects the authors discuss the similarities and differences in the various tax law approaches, including observations and conclusions on the significance of these comparisons.

目次

  • The trust - an introduction, Frans Sonneveldt
  • trusts and tax consequences in the United Kingdom, Frans Sonneveldt
  • the taxation of trusts, beneficiaries and grantors in the United States of America, Bert R. Leemreis
  • the trust and Swiss tax law, Harrie L. van Mens
  • the trust and Dutch law - the trust and Netherlands' individual income tax, net wealth tax and corporate income tax, Harrie L. van Mens
  • the trust and Dutch law - trusts, gifts and inheritance tax in the Netherlands, Bert R. Leemreis
  • France - a law proposal introducing "La Fiducie", Ineke A. Koele
  • trusts and the application of the OECD model convention, Ineke A. Koele.

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