The Nature of the Beneficiary’s Interest in English, Japanese and Quebec Trusts

In the English trust, beneficiary is viewed as substantive owner of property held under even trustee holds legal title to and only party who able perform functions associated with ownership. mixed systems Quebec Japan, juristic pathways beneficiary’s ownership are vastly different. case arguably ‘patrimony’ conception applicable, whereas in new ‘ownerless’ trust departed significantly from problems trustee’s ‘ownership’ old trust. The article submits that ability enforce his interests independently other parties crucial trust’s achieve broadly similar effects law. From an perspective, it vital civilian trusts recognize accommodate differences inherent rights due administration economic enjoyment property.