FIDUCIA ŞI TRUST-UL PRIN PRISMA REGLEMENTĂRILOR DIN DIFERITE STATE

Abstract

This article provides an overview of trust or fiducia regulations in different states. Based on the application of historical, systemic, and comparative analysis methods, the research led to the identification of the main regulations and to a brief characteristic of these institutions in the light of several common-law jurisdictions (UK, USA), mixed law jurisdictions (the trust model in the Canadian province of Quebec) and civil law jurisdictions (the trust/ fiducia model in France, Romania, the Republic of Moldova and China).