A Comparative Study On Charitable Trust System

Trust is a property management system and an effective form of financing, which has been experienced for centuries. It originated in an equitable environment in the United Kingdom, and developed in the United States. At present, the system has been recognized in many other counties. Charitable trust is an important classification of trust, which plays an important role in promoting the harmonious development of modern society. However, it is not difficult to found that charitable trust system among the non-native environment for migration and development is not smooth sailing. Opinions differ on charitable trust in the non-Anglo-American legal systems.The source of charitable trust system, the historical development, the establishment of conditions of charitable trust, internal operation and external supervision, the factors affecting the development of charitable trust, the concrete practices are the main line of this paper, which is enriched through the comparative analysis of Anglo-American legal systems and Continental law system in the above aspects.The purpose of this paper is finding the root reason of development difference of charitable trust between different countries and attempt to build charitable trust system envisaged in China's legislation.This article contains four sections. The using of writing are the comparative analysis, the text analysis, the sociological of law analysis.