Countries which derive their land holding systems from the common law often face the problem of divided ownership between buildings and the land on which they stand. The problem has been approached in differing ways. The United States, for example, has the concept of condominium ownership. Australia, among others, utilises the sophisticated Torrens strata title system. Others, in contrast, have often struggled to adopt less flexible principles to modern, changing requirements.

In the United Kingdom, the solution has often taken the form of the 'long lease'. This paper, which very much represents the initial findings of a comprehensive project involving international comparisons traces, by means of Government papers and reports, courts and tribunal decisions, the political and legislative framework underpinning the development of enfranchisement and the right to buy, seeking to identify legal and valuation problems and the extent to which these have been or may be resolved.