A need for greater understanding of civil law entities by common law jurisdictions
Bibliographic record
Abstract
In the course of the last six months, the ratification by the Swiss parliament of The Hague Convention of 1 July 1985 on the Law Applicable to Trusts and on their Recognition has generated much attention. There has also been much discussion regarding the fact that, while the Convention was ratified, nowhere near as much progress has been made with respect to the administration of trusts from Switzerland, be it for Swiss families or families around the world. These comments typically come from advisers, lawyers and banks, primarily, although not limited to, the trust business outside of Switzerland. That being said, in most common law countries knowledge of the civil law equivalents of trusts, particularly, the ‘Stiftung’, the ‘Anstalt’ and the trust reg., is dramatically lacking. Instead of common law jurisdictions focusing on how trusts may be used within Switzerland and in other civil law jurisdictions, we would encourage common law jurisdictions, particularly Canada, the United States, the United Kingdom, Australia and New Zealand to focus much more on their understanding and recognition of the traditional civil law wealth management vehicles. It is, for instance, quite surprising that the US tax treatment of a ‘Stiftung’ is, at best, unclear, due in large part to the fact that ‘Stiftungen’ are not properly understood.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.067 | 0.073 |
| Meta-epidemiology (narrow) | 0.002 | 0.002 |
| Meta-epidemiology (broad) | 0.004 | 0.002 |
| Bibliometrics | 0.010 | 0.008 |
| Science and technology studies | 0.009 | 0.123 |
| Scholarly communication | 0.032 | 0.162 |
| Open science | 0.010 | 0.015 |
| Research integrity | 0.023 | 0.058 |
| Insufficient payload (model declined to judge) | 0.010 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".