英美财产法历来被誉为最难理解的法律制度之一。英美财产法中至今还保留着大量的土地法词汇,如“fee simple”等。这些词汇今天仍被沿用,但其内涵已发生了重大变化,这对理解英美财产法带来了困难。英美财产法不仅古老、复杂,而且与大陆法系的财产法区别甚大。大陆法系以所有权为基础来分析财产和财产权,但在英美法律中却几乎找不到一个与 The Anglo-American Property Law has long been hailed as one of the most difficult to understand legal systems. The Anglo-American Property Law still retains a lot of land law vocabulary, such as “fee simple ” and so on. These terms are still used today, but their content has undergone major changes that have caused difficulties in understanding the Anglo-American property laws. The Anglo-American Property Law is not only ancient and complex, but also differs greatly from the property law of the civil law system. The civil law system analyzes the property and property rights on the basis of the ownership, but in Anglo-American law it almost can not find a