By comparing English, Mexican, and French trust law, it is possible to shed light on the successes and shortcomings of each jurisdiction and, by this, propose principles for an ideal regime of the express trust. The comparison starts by analyzing the personal elements of the express trust and continues with the study of its real elements. Proposing an ideal regime can be a theoretical basis for future reforms introducing or improving the trust in civil and common law jurisdictions.
Ibarra Garza, R. (2020). An ideal regime for the express trust—a comparative analysis: English, French, and Mexican law. Trusts & Trustees, 26(4), 336–346. https://doi.org/10.1093/tandt/ttaa018