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The paper is an attempt in conceptual analysis of the theoretical model of the foundation (Stiftung) in civil law jurisdictions. It concerns correlation between corporations and non-corporate legal persons in Germanic countries and the issue of non-profit organizations along with its applicability to the concept of foundation. On the basis of the German legal doctrine differentia specifica of the foundation is defined to reflect the ideal model of the foundation as a separate form of legal persons.
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D.P. ZAIKIN (2020) studied this question.
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