The institution of the trust, a creature of the English Court of Equity, evolved deep in the bosom of the Anglo-American legal tradition. France, a civil jurisdiction, lacks a legal institution that is truly comparable. Her courts are even reluctant to recognize trusts that are duly created in common law jurisdictions, such as New York, England, and Australia. How is it, then, that so much of trust law’s legal terminology is in French? The answer may be found in Loring and Rounds: A Trustee’s Handbook § 8.15 (2013), at pages 1043-1045. The said § 8.15 is reproduced in its entirety below.
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