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Author: Wolfgang Faber Publisher: Walter de Gruyter ISBN: 386653700X Category : Law Languages : en Pages : 281
Book Description
Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.
Author: Wolfgang Faber Publisher: Walter de Gruyter ISBN: 386653700X Category : Law Languages : en Pages : 281
Book Description
Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.
Author: Lars Peter Wunibald van Vliet Publisher: ISBN: Category : Conditional sales Languages : en Pages : 270
Book Description
The subject-matter of this book is the transfer of movable property in German, French, English and Dutch law. Of particular importance is the division into the three main types of transfer system: the causal consensual system, the causal tradition system and the abstract tradition system. Here two dividing lines intertwine: the distinction between causal and abstract systems and the distinction between consensual and tradition systems. Often the existence of three different transfer systems is seen as a complicating factor in harmonizing European private law. Yet, the book demonstrates that the division between consensual systems and tradition systems and the division between causal and abstract systems are not unbridgeable.
Author: Martin Lilja Publisher: Peter Lang Gmbh, Internationaler Verlag Der Wissenschaften ISBN: 9783631649428 Category : Personal property Languages : en Pages : 0
Book Description
The book discusses legal rules for three functional commercial conflict situations under the laws of the U.S.A. (the U.C.C. etc.) on the protection of a buyer in the seller's insolvency, the protection of a seller in the buyer's insolvency, and the conflict between a person formerly entitled to the goods and a good faith acquirer.
Author: Wolfgang Faber Publisher: Sellier European Law Pub ISBN: 9783866531376 Category : Law Languages : en Pages : 586
Book Description
This is the sixth and last volume of a series of national reports on basic issues concerning the acquisition and loss of ownership of movable assets. The series covers 28 European legal systems. Starting with general property law issues like the concepts of ownership and possession employed in the respective legal systems, and the related means of protection, the reports primarily deal with the `derivative' transfer of ownership, but extend to good faith acquisition from a non-owner, acquisitive prescription, processing and commingling, and further related issues. The reports provide the reader with detailed information about the respective rules, case law and legal literature, prepared by national property law experts. These reports are a starting point for further comparative research in property law and also a tool for practitioners searching for information on foreign legal systems.
Author: Wolfgang Faber Publisher: ISBN: Category : Languages : en Pages :
Book Description
Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.
Author: Eva-Maria Kieninger Publisher: Cambridge University Press ISBN: 1139454757 Category : Law Languages : en Pages : 827
Book Description
For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union. Following the Common Core approach, the national reports are centred around fifteen hypothetical cases dealing with the most important issues of secured transactions law, such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions law.
Author: Wolfgang Faber Publisher: Walter de Gruyter ISBN: 3866537018 Category : Law Languages : en Pages : 649
Book Description
This is the first of a series of national reports on basic issues concerning the acquisition and loss of ownership of movable assets. The series is planned to cover 27 European legal systems, distributed over six volumes, as a product of the research activities of the working group "Transfer of Movables" within the "Study Group on a European Civil Code". Starting with general property law issues like the concepts of ownership and possession employed in the respective legal systems, and the related means of protection, the reports primarily deal with the "derivative" transfer of ownership, but extend to good faith acquisition from a non-owner, acquisitive prescription, processing and commingling, and further related issues. The reports provide the reader with detailed information about the respective rules, case law and legal literature, prepared by national property law experts. These reports are a starting point for further comparative research in property law and also a tool for practitioners searching for information on foreign legal systems. Where available and as far as reasonable, the reports include translations of the most important statutory provisions either in the text or in an annex. All reports include a table of literature and a table of abbreviations, which shall facilitate carrying out further research.
Author: Janeen M. Carruthers Publisher: Oxford Private International L ISBN: 9780199271474 Category : Law Languages : en Pages : 0
Book Description
This book provides a detailed and up-to-date exposition of English and Scottish rules of choice of law in inter vivos transfers of property. It traces the development of the lex situs rule, and its application to inter vivos dealings with immovable property, tangible movable property(including the special case of cultural property), and intangible movable property (including indirectly held securities).The author offers two alternative models of suggested choice of law rules in property, introducing a greater degree of flexibility into choice of law rules in property, and formulates even-handed solutions to the complex problems of space, time and policy which arise in this area of the conflict oflaws.
Author: Michele Graziadei Publisher: Edward Elgar Publishing ISBN: 1785369164 Category : Law Languages : en Pages : 520
Book Description
Comparative Property Law provides a comprehensive treatment of property law from a comparative and global perspective. The contributors, who are leading experts in their fields, cover both classical and new subjects, including the transfer of property, the public-private divide in property law, water and forest laws, and the property rights of aboriginal peoples. This Handbook maps the structure and the dynamics of property law in the contemporary world and will be an invaluable reference for researchers working in all domains of property law.
Author: Wolfgang Faber Publisher: Sellier European Law Pub ISBN: 9783866531185 Category : Law Languages : en Pages : 723
Book Description
This is the fourth volume of a series of national reports on basic issues concerning the acquisition and loss of ownership of movable assets. The series covers 28 European legal systems. Starting with general property law issues like the concepts of ownership and possession employed in the respective legal systems, and the related means of protection, the reports primarily deal with the `derivative' transfer of ownership, but extend to good faith acquisition from a non-owner, acquisitive prescription, processing and commingling, and further related issues. The reports provide the reader with detailed information about the respective rules, case law and legal literature, prepared by national property law experts. These reports are a starting point for further comparative research in property law and also a tool for practitioners searching for information on foreign legal systems.
Author: Wolfgang Faber
Author: Wolfgang Faber
Author: Lars Peter Wunibald van Vliet
Author: Martin Lilja
Author: Wolfgang Faber
Author: Wolfgang Faber
Author: Eva-Maria Kieninger
Author: Wolfgang Faber
Author: Janeen M. Carruthers
Author: Michele Graziadei
Author: Wolfgang Faber