Comparison with the Anglo-American Trust
The Private Foundation is an interesting alternative to the Trust, especially in the so-called civil law jurisdictions. In the Western-European continental legal systems, the Trust is still an unknown phenomenon. This also counts for jurisdictions based upon these legal systems, such as most of the Latin American countries. The Trust is a typical product of the so-called common law legal systems, with England/UK and most of the states of the USA as the best known exponents.
The legal systems that are based upon the Code Civil do not know the distinction between legal ownership and beneficial ownership that is so typical for the Trust.
