“I have recently defended my PhD thesis at UCL, which focuses on trusts law in Japan as well as Quebec from an English legal perspective. The thesis has two parts: first, I aim to show that the structures of Japanese and Quebec trusts are highly similar to English express trusts, understood as a set of legal rules which restrict the authority of the trustee as titleholder to property, and which has important effects on property law in the host legal system. Secondly, the thesis argues that civil law countries’ relative disinterest in understanding as a single body of rules what common lawyers describe as ‘fiduciary’ principles explains the lack of appreciation of the trustee’s discretionary powers in Japan …” (more)
[Joyman Lee, BACL, 8 July]
First posted 2022-07-08 15:00:44
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