No, I don't see any difference. The approach they use of course is to use the trust in the context of their federal system. A difference between U.S. law and our law is that their Congress has much more power than our Parliament to invade a state law. We're much more strict with our Constitution, quite properly.
It was for this reason that I concluded that the only practical way to legally implement something that would be equivalent to the American approach was to use insolvency, which is a clear federal basis for acting in this area.