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nue propriété

English translation: bare ownership

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GLOSSARY ENTRY (DERIVED FROM QUESTION BELOW)
French term or phrase:nue propriété
English translation:bare ownership
Entered by: xxxPoveyTrans
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00:49 Nov 2, 2006
French to English translations [PRO]
Real Estate
French term or phrase: nue propriété
concernant la nue propriété ; pour l’instant je n’ai pas fait de testament mais

does this mean empty or undeveloped or something else?
xxxPoveyTrans
Local time: 10:43
bare ownership
Explanation:
Baleyte et al, “Dictionnaire économique et juridique”, gives “ownership without usufruct or use, bare ownership” for “nue-propriété”. Note the spelling with hyphen, which is how I always thought it was spelt.
Selected response from:

Richard Benham
France
Local time: 11:43
Grading comment
Thanks Richard
4 KudoZ points were awarded for this answer

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Summary of answers provided
4 +8bare ownership
Richard Benham
4 -1owned property without rights of use/owned property without usufructMatthewLaSon
3reversionary interest [in a property]
a05


Discussion entries: 2





  

Answers


14 mins   confidence: Answerer confidence 4/5Answerer confidence 4/5 peer agreement (net): +8
nue-propriété
bare ownership


Explanation:
Baleyte et al, “Dictionnaire économique et juridique”, gives “ownership without usufruct or use, bare ownership” for “nue-propriété”. Note the spelling with hyphen, which is how I always thought it was spelt.

Richard Benham
France
Local time: 11:43
Native speaker of: Native in EnglishEnglish
PRO pts in category: 10
Grading comment
Thanks Richard

Peer comments on this answer (and responses from the answerer)
agree  writeaway: confirmed by other explanations (in French) and fwiw: http://www.proz.com/kudoz/1116346
1 hr
  -> Thanks.

agree  Fabio Descalzi
1 hr
  -> Thanks.

neutral  MatthewLaSon: I would say "bare property" if you insist on the word "bare." I don't agree with all dictonaries. In fact, I don't like "bare ownership" as it seems to be only used in texts translated from French. Put it in plain English if there isn't a fixed term.
1 hr
  -> I don't insist on "bare", but I don't see the argument for "property" either. More context would be needed to make out a case either way. One reason why "bare ownership" only occurs in translations from French is that there is no common-law equivalent.

agree  IanDhu
5 hrs
  -> Thanks.

agree  Assimina Vavoula
5 hrs
  -> Thanks.

agree  xxxcmwilliams
7 hrs
  -> Thanks.

agree  Mary Lalevee
8 hrs
  -> Thanks.

agree  Rafael Wugalter: Absolutely. Bare ownership. It is dangerous to translate documents into another legal system because both systems don't always work the same way and this can come back and bite you,
11 hrs
  -> Thanks.

agree  Miranda Joubioux: You might find this document interesting http://www.iclg.co.uk/khadmin/Publications/pdf/660.pdf
11 hrs
  -> Thanks. I do, but mainly because I'm thinking of buying real estate overseas myself. I already knew about “nue-propriété”!
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4 hrs   confidence: Answerer confidence 3/5Answerer confidence 3/5
reversionary interest [in a property]


Explanation:
a less common but more legalistic translation

nue-propriété - reversionary interest where the purchaser has no occupational rights over the property until the death or prior surrender of the life tenant


    Reference: http://estateagent.clifton-media.co.uk/buying_process/word_d...
    Reference: http://www.answers.com/topic/reversionary-interest
a05
Native speaker of: Native in RussianRussian
PRO pts in category: 8

Peer comments on this answer (and responses from the answerer)
neutral  Richard Benham: This is kinda OK; I think there is a lot of overlap between "nue-propriété" and "reversionary interest", but they are not the same. My approach in these cases is to translate as literally as possible, rather than use a legalism that may cloud the issue.
1 hr
  -> thank you, I agree and usually defend making clear distinction netween common and continental law. In this case, just wanted a broader vision in addition to a calque

neutral  Rafael Wugalter: Moreover, the concept of "reversion" is a common-law concept and is not used in the civil law of continental Europe etc.
7 hrs
  -> thank you, see above
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2 hrs   confidence: Answerer confidence 4/5Answerer confidence 4/5 peer agreement (net): -1
owned property without rights of use/owned property without usufruct


Explanation:
Hello,

I do not prefer the term "bare ownership." I have never seen it used in US. I think that it should be explained in clearer terms.

By the way,

propriétaire = owner
propriété = property (not "ownership" as it can mean at times)

I hope this helps.

--------------------------------------------------
Note added at 4 hrs (2006-11-02 05:39:51 GMT)
--------------------------------------------------

I still believe that this has to do with property, not ownership. That said, I have seen cases where "propriété" means ownership, not property.

You really have to study the context to be certain of the correct meaning of the French noun.

MatthewLaSon
Local time: 05:43
Native speaker of: Native in EnglishEnglish
PRO pts in category: 108

Peer comments on this answer (and responses from the answerer)
neutral  Richard Benham: I don't see the argument for "property" over "ownership". If, for example, as seems likely, the writer has just made a dispositon relating to the usufruct of the same piece of land, then "property" would be dead wrong and "ownership" correct.
1 hr
  -> Thanks, Richard. You are right: It is not blatantly clear whether we are dealing with "property" or "ownership." At any rate, I am still leaning towards "property."

neutral  writeaway: check French legal dicos and along with bilingual dicos. this has to do with ownership, not property. at least this new answer is not a complete contresens. Read the definition in Dalloz-it's about ownership rights
7 hrs
  -> What you own is your "property", although I see your point.

neutral  Rafael Wugalter: The fact is that "civil law English" exists. It is used in Quebec, the Philippines, and Louisiana, among other places. If people won't understand it, write them a footnote.
9 hrs

disagree  xxxdf49f: propriété in this standard French legalese phrase means ownership and NOT property, this is perfectly clear to anyone familiar with French language and French law, no ambiguity and no need to "study the context"
12 hrs
  -> What you own is your "property." Your property is referring to your ownership.

neutral  rkillings: In fact, because of Louisiana, the received term in the US is "naked ownership". That's why you've never seen the "bare" modifier.:-)
2591 days
  -> Thank you, rkillings! I appreciate your wealth of knowledge.
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