In certain civil law jurisdictions (e.g.,

France France (), officially the French Republic ( ), is a country primarily located in Western Europe. It also comprises of Overseas France, overseas regions and territories in the Americas and the Atlantic Ocean, Atlantic, Pacific Ocean, Pac ...

Quebec Quebec ( ; )According to the Canadian government, ''Québec'' (with the acute accent) is the official name in Canadian French and ''Quebec'' (without the accent) is the province's official name in Canadian English is one of the thirte ...

Mexico Mexico (Spanish language, Spanish: México), officially the United Mexican States, is a List of sovereign states, country in the southern portion of North America. It is borders of Mexico, bordered to the north by the United States; to the so ...

, etc.), the patrimoine d'affectation is

property Property is a system of rights that gives people legal control of valuable things, and also refers to the valuable things themselves. Depending on the nature of the property, an owner of property may have the right to consume, alter, share, r ...

, assets, or a legal estate that can be divided for a fiduciary purpose, as being distinct from a person's general assets. It is similar in some respects to the way under

common law In law, common law (also known as judicial precedent, judge-made law, or case law) is the body of law created by judges and similar quasi-judicial tribunals by virtue of being stated in written opinions."The common law is not a brooding omniprese ...

property is held, managed, or invested in trust by a trustee for the benefit of third parties (beneficiaries). The affected property remains outside the grantor's assets; therefore, even if the grantor goes bankrupt, becomes insolvent, or incurs liabilities, the property remains untouchable and may continue to benefit the intended beneficiaries. Originally proposed as a way of explaining the common law trust, the concept was first put forward by the French jurist Pierre LepaullePierre Lepaulle, ''Traité théorique et pratique des trusts en interne, en droit fiscale international'' (Paris: Rousseau et Cie, 1932). who based it on the German ''Zweckvermögen''.

References

Civil law (legal system) {{Law-stub