Trust testamentario sottoposto a legge straniera e norme inderogabili di diritto successorio italiano. Un’analisi della prassi negoziale

Di Lucilla Gatt -
The operation of the trust, i.e. that form of patrimonial destination having a negotiated source based on foreign law models, still appears problematic in our legal system although more then thirty years have been passed not only since the signing of the Hague Convention on trust but, above all, from the diffusion of this figure in the Italian negotiation practice, a diffusion which, however, hasn’t been accompanied by a “serene” application of the (mandatory) rules of Italian law to this figure. The object of this investigation are some questions that emerge, in fact, from the real forms that trust takes in practice with specific reference to the so-called trust mortis causa. This is . . .