It is considered that there are several types of ‘de’ morpheme in Mandarin Chinese but a unified conclusion has not been successfully drawn from the previous approaches and studies. Scholars such as Li and Thompson (1981) argue that one kind of 'de' morpheme is a possessive marker while Cheng (1986) argues that ‘de’ is a complementizer. The aim of this research is to test the assumption that 'de' may assign genitive case in Chinese. Based on Chomsky’s (2015) and Carnie’s (2013, 2021) X-bar theories, a crosslinguistic study on ‘de’ morpheme has been carried out. Moreover, Chomsky’s (2015) analysis of the interface between logical form (LF) and phonetic form (PF) gives justification for the elliptical (covert) ‘de’ in certain cases. As far as syntactic structures are concerned, there is a discussion on the recursion of determiner phrases and the results of such analysis suggest that ‘de’ (Mandarin),’s (English) and ‘de’ (Spanish) can be considered genitive case markers.