Part II

Gerhard HOHLOCH, Ph.D. in Law Professor, Director of the Institute of International Private Law and Comparative Law, University of Fribourg/Brisgau, Property and Trust in Common Law
Law of Property – the property regime – is part of the Common Law. Law of Property gathers the Law of Property in Land and the Personal Property.  The main difference between these institutions of Common Law and the similar institutions in Continental Law is the absence of a written law.
Trust is a specific institution in Common Law. Though there is no similar institution in Continental Law, a parallel can be made.  A Trust can be found based on a legal act or upon law (by operation of Law).

Keywords: comparative law, common law, law of property, trust.
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