In the past decade a comparative law and economics literature has emerged that is largely organized around an effort to explain differences in country economic performance in terms of differences between common law and civil code systems. Assumptions about differences between common law and...

The new comparative economics is largely organized around an effort to explain differences in country economic performance in terms of differences between common law and civil code systems. Assumptions about differences between common law and civil code regimes and the correspondence between...

By contrast to the common law that governs the other Canadian provinces and territories, Quebec's distinctive civilian private law understands the concept of “gift” not as a separate legal category, but as a particular kind of contract by which one party, the donor, conveys property...

This paper examines one of the most important concepts of intestate succession – inheritance by right of representation. The following analysis is based on civil law in Russia and France.The paper provides an overview of the meaning and the role of the right of representation, determines those...

Introduction : creditworthiness and 'responsible credit' -- Creditworthiness assessment as a macroprudential duty -- Creditworthiness for individuals : methodologies and legal issues -- Creditworthiness assessment and other contractual duties as tools of 'responsible credit' : the case of...