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Archive | 2004

Security Rights in Movable Property in European Private Law

Eva-Maria Kieninger; Michele Graziadei

Part I. Introduction and context: 1. Introduction Eva-maria Kieninger 2. A labyrinth of creditors Willem J. Zwalve 3. Security in movables in the United States Harry C. Sigman 4. The English law of security Michael Bridge 5. The European Bank for Reconstruction and Developments Secured Transactions project Frederique Dahan and John Simpson Part II. The Case Studies Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger Indexes.


Archive | 2005

Commercial Trusts in European Private Law: The case studies

Michele Graziadei; Ugo Mattei; Lionel Smith

This book examines the law governing asset management in a wide range of commercial contexts across 15 jurisdictions of the European Union. The study includes the basic features of the available legal institutions (for example, whether they provide bankruptcy protection or allow free choice of governing law) and specialized applications in particular fields (such as pensions and collective investment schemes). Produced with a team of over 20 contributors, it is the latest volume to appear from the Trent-based project The Common Core of European Private Law. The volume begins with a study of the history of comparative law scholarship in the field of trusts, situating the current work in the field and addressing the thorny issue of terminology. The comparative data are structured, according to the Common Core methodology, around hypothetical questions and responses from national reporters. The authors present comparative conclusions regarding the reports and a discussion of the issues raised for further study. The volume also includes an essay by Donovan Waters QC on the Hague Convention on the Law Applicable to Trusts and on their Recognition.


Archive | 2005

Commercial Trusts in European Private Law: List of abbreviations

Michele Graziadei; Ugo Mattei; Lionel Smith

This book examines the law governing asset management in a wide range of commercial contexts across 15 jurisdictions of the European Union. The study includes the basic features of the available legal institutions (for example, whether they provide bankruptcy protection or allow free choice of governing law) and specialized applications in particular fields (such as pensions and collective investment schemes). Produced with a team of over 20 contributors, it is the latest volume to appear from the Trent-based project The Common Core of European Private Law. The volume begins with a study of the history of comparative law scholarship in the field of trusts, situating the current work in the field and addressing the thorny issue of terminology. The comparative data are structured, according to the Common Core methodology, around hypothetical questions and responses from national reporters. The authors present comparative conclusions regarding the reports and a discussion of the issues raised for further study. The volume also includes an essay by Donovan Waters QC on the Hague Convention on the Law Applicable to Trusts and on their Recognition.


Archive | 2005

Commercial Trusts in European Private Law: Contributors to the volume

Michele Graziadei; Ugo Mattei; Lionel Smith

This book examines the law governing asset management in a wide range of commercial contexts across 15 jurisdictions of the European Union. The study includes the basic features of the available legal institutions (for example, whether they provide bankruptcy protection or allow free choice of governing law) and specialized applications in particular fields (such as pensions and collective investment schemes). Produced with a team of over 20 contributors, it is the latest volume to appear from the Trent-based project The Common Core of European Private Law. The volume begins with a study of the history of comparative law scholarship in the field of trusts, situating the current work in the field and addressing the thorny issue of terminology. The comparative data are structured, according to the Common Core methodology, around hypothetical questions and responses from national reporters. The authors present comparative conclusions regarding the reports and a discussion of the issues raised for further study. The volume also includes an essay by Donovan Waters QC on the Hague Convention on the Law Applicable to Trusts and on their Recognition.


Archive | 2005

Commercial Trusts in European Private Law: Frontmatter

Michele Graziadei; Ugo Mattei; Lionel Smith

This book examines the law governing asset management in a wide range of commercial contexts across 15 jurisdictions of the European Union. The study includes the basic features of the available legal institutions (for example, whether they provide bankruptcy protection or allow free choice of governing law) and specialized applications in particular fields (such as pensions and collective investment schemes). Produced with a team of over 20 contributors, it is the latest volume to appear from the Trent-based project The Common Core of European Private Law. The volume begins with a study of the history of comparative law scholarship in the field of trusts, situating the current work in the field and addressing the thorny issue of terminology. The comparative data are structured, according to the Common Core methodology, around hypothetical questions and responses from national reporters. The authors present comparative conclusions regarding the reports and a discussion of the issues raised for further study. The volume also includes an essay by Donovan Waters QC on the Hague Convention on the Law Applicable to Trusts and on their Recognition.


Archive | 2005

Commercial Trusts in European Private Law: Index

Michele Graziadei; Ugo Mattei; Lionel Smith

This book examines the law governing asset management in a wide range of commercial contexts across 15 jurisdictions of the European Union. The study includes the basic features of the available legal institutions (for example, whether they provide bankruptcy protection or allow free choice of governing law) and specialized applications in particular fields (such as pensions and collective investment schemes). Produced with a team of over 20 contributors, it is the latest volume to appear from the Trent-based project The Common Core of European Private Law. The volume begins with a study of the history of comparative law scholarship in the field of trusts, situating the current work in the field and addressing the thorny issue of terminology. The comparative data are structured, according to the Common Core methodology, around hypothetical questions and responses from national reporters. The authors present comparative conclusions regarding the reports and a discussion of the issues raised for further study. The volume also includes an essay by Donovan Waters QC on the Hague Convention on the Law Applicable to Trusts and on their Recognition.


Archive | 2004

Security Rights in Movable Property in European Private Law: Index by country

Eva-Maria Kieninger; Michele Graziadei; George L. Gretton; Cornelius G. van der Merwe; Matthias E. Storme

Part I. Introduction and context: 1. Introduction Eva-maria Kieninger 2. A labyrinth of creditors Willem J. Zwalve 3. Security in movables in the United States Harry C. Sigman 4. The English law of security Michael Bridge 5. The European Bank for Reconstruction and Developments Secured Transactions project Frederique Dahan and John Simpson Part II. The Case Studies Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger Indexes.


Archive | 2004

Security Rights in Movable Property in European Private Law: The case studies

Eva-Maria Kieninger; Michele Graziadei; George L. Gretton; Cornelius G. van der Merwe; Matthias E. Storme

Part I. Introduction and context: 1. Introduction Eva-maria Kieninger 2. A labyrinth of creditors Willem J. Zwalve 3. Security in movables in the United States Harry C. Sigman 4. The English law of security Michael Bridge 5. The European Bank for Reconstruction and Developments Secured Transactions project Frederique Dahan and John Simpson Part II. The Case Studies Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger Indexes.


Archive | 2004

Security Rights in Movable Property in European Private Law: Frontmatter

Eva-Maria Kieninger; Michele Graziadei; George L. Gretton; Cornelius G. van der Merwe; Matthias E. Storme

Part I. Introduction and context: 1. Introduction Eva-maria Kieninger 2. A labyrinth of creditors Willem J. Zwalve 3. Security in movables in the United States Harry C. Sigman 4. The English law of security Michael Bridge 5. The European Bank for Reconstruction and Developments Secured Transactions project Frederique Dahan and John Simpson Part II. The Case Studies Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger Indexes.


Archive | 2004

Security Rights in Movable Property in European Private Law: Introduction and context

Eva-Maria Kieninger; Michele Graziadei; George L. Gretton; Cornelius G. van der Merwe; Matthias E. Storme

Part I. Introduction and context: 1. Introduction Eva-maria Kieninger 2. A labyrinth of creditors Willem J. Zwalve 3. Security in movables in the United States Harry C. Sigman 4. The English law of security Michael Bridge 5. The European Bank for Reconstruction and Developments Secured Transactions project Frederique Dahan and John Simpson Part II. The Case Studies Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger Indexes.

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Benoit Allemeersch

Katholieke Universiteit Leuven

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Ugo Mattei

University of California

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