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This book discusses recent and anticipated developments concerning trust arbitration in a variety of domestic and cross-border settings. In so doing, the text not only provides necessary information about the special nature of national and international trust arbitration, it also bridges the gap between trust law and arbitration law by bringing together authors with expertise in both fields. 0Furthermore, this book is the first to provide detailed and critical analysis of various institutional initiatives in the area of trust arbitration (including measures proposed by the American Arbitration Association, the American College of Trust and Estate Counsel, the English Trust Law Committee, and the International Chamber of Commerce) and to offer in-depth coverage of various national, international, and comparative issues, including the applicability of the New York Convention and the Hague Trust Convention to internal trust arbitration. As a result, this book is a must-have for specialists in both trust law and arbitration law

This article analyses if and in which direction investment tribunal in intra-EU investment arbitration would apply EU law and if it could at least take it into account by decision making process. It considers three approaches in which EU law and its rules could be relevant. First, EU law is a system based on international treaties, and is therefore a part of international law Second, in consequence of the doctrine of direct effect, rules of the EU law automatically become a part of legal orders of member states, and from the point of view of investment tribunal these rules are part of the legal order of host state. Third, EU law can be in international investment arbitration relevant as a fact. ; This article analyses if and in which direction investment tribunal in intra-EU investment arbitration would apply EU law and if it could at least take it into account by decision making process. It considers three approaches in which EU law and its rules could be relevant. First, EU law is a system based on international treaties, and is therefore a part of international law Second, in consequence of the doctrine of direct effect, rules of the EU law automatically become a part of legal orders of member states, and from the point of view of investment tribunal these rules are part of the legal order of host state. Third, EU law can be in international investment arbitration relevant as a fact.

1 The School of International Arbitration -- 1 The birth of the School of International Arbitration -- 2 The School of International Arbitration: aspirations and objects -- 3 International arbitration — teaching and research -- 2 The jurisdiction and authority of arbitrators -- 4 ICSID arbitration -- 5 States in the international arbitral process -- 6 The sources and limits of the arbitrator's powers -- 7 Determination of arbitrators' jurisdiction and the public policy limitations on that jurisdiction -- 8 The sources and limits of the arbitrator's powers in England -- 9 The law applicable to the merits of the dispute -- 10 The applicable law: general principles of law — the lex mercatoria -- 11 The law governing the agreement and procedure in international arbitration in England -- 3 International arbitration procedure -- 12 The extent of independence of international arbitration from the law of the situs -- 13 The role of national law and the national courts in England -- 14 The role of the courts under the UNCITRAL model law script -- 15 Supplementary rules governing the presentation and reception of evidence in international commercial arbitration -- 16 Judicial assistance for the arbitrator -- 17 The supervisory and adjunctive jurisdiction of American courts in arbitration cases -- 18 The conduct of ICC arbitration proceedings -- 19 The conduct of arbitration proceedings under English law -- 20 Finality of arbitral awards and judicial review -- 4 International arbitration involving states and state-entity parties -- 21 The strengths and weaknesses of international arbitration involving a state as a party -- 22 Disputes between states and foreign companies -- 23 The strengths and weaknesses of international arbitration involving a state as a party: practical implications -- 24 International arbitration between states and corporate entities: a cautionary note -- 25 Settlement of disputes within the framework of foreign debt rescheduling in Latin American countries -- 26 Arbitration with foreign states or state-controlled entities: some practical questions -- 27 Structuring the arbitration in advance — the arbitration clause in an international development agreement -- 28 Sovereign immunity and transnational arbitration -- 29 Sovereign immunity and arbitration -- 30 Enforcement of arbitral awards in Eastern Europe -- 31 The recognition and enforcement of foreign arbitral awards in the states of the Arab Middle East -- 32 So far, so good: enforcement of foreign commercial arbitration awards in United States courts -- 33 The enforcement of arbitral awards against a state: the problem of immunity from execution.