When comparing the laws of different jurisdictions, one often sees only the forest or the trees. This is particularly problematic in comparative company law, where students hope both to understand the overall framework of the law and grasp its practical application. This text's structure, now in its second edition, solves that dilemma. Chapters open with discursive analyses of the law in each of Germany, the UK and the US (Delaware, the ABA Model Business Corporation Act, and federal securities laws) and set out the high-level governing framework, particularly for the EU and its member states. This analysis is succinct and pointed, with numerous references to both the law and leading scholarship. The whole text is arranged to highlight comparative aspects. Diagrams are used where helpful. Chapters close with edited judicial decisions from at least two of the jurisdictions discussed, which allows fresh exploration of comparison in more detail, and pointed questions to guide class discussion.
R Booth, Capital Requirements in United States Corporation Law' in M Lutter (ed), Legal Capital in Europe (de Gruyter Recht 2006) 620,626. * Manning and Hanks (n 4) 42. ** ibid 30. * Berle and Means (n 25) 146. performance by a third ...
The overall purpose of this book is therefore to fill a gap in the literature by identifying whether conceptual differences between countries exist.
At a time of rapid development of EU and national company laws, this book will aid the understanding of an emerging discipline.
The book also has a public policy dimension, because the existence or absence of differences may lead to the question of whether formal harmonisation of company law is necessary. The book covers 10 legal systems.
This book presents a comprehensive study on how twenty-three countries have approached the issue of company groups.
The book covers the lifespan of a company, from formation to eventual dissolution, and offers detailed explanations of each stage alongside extracts from important court decisions that show how the law works in practice in each jurisdiction ...
This research handbook provides a state-of-the-art perspective on how corporate governance differs between countries around the world.
Comparative Corporate Governance furthers this goal by bringing together current scholarship in law and economics with the expertise of local corporate governance specialists from twenty-three countries.
The general provisions of the Aktiengesetz setting out the duty of care of statutory board members do not protect shareholders." Shareholders may therefore not claim compensation for loss caused by board members who have breached their ...
This successful textbook remains the only offering for students of European company law, and has been fully updated.