By Andreas Cahn
It may be tough for college kids of comparative corporation legislations either to appreciate the across the world relative nature of a criminal approach and clutch it in useful element. This publication is designed to deal with that challenge. each one bankruptcy starts off with a discursive research of the legislation in Germany, the united kingdom and the us, framed via a comparative presentation. Chapters additionally comprise edited judicial judgements from at the very least of the jurisdictions, which enable readers to accomplish their very own comparisons in additional element and go away room for unique research and dialogue.
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Extra info for Comparative Company Law: Text and Cases on the Laws Governing Corporations in Germany, the UK and the USA
Example text
64 According to the State of Delaware’s Division of Corporations, consulted in June 2009, 850,000 legal entities have been established in the state, including 63 percent of Fortune 500 companies and over half of all US publicly traded companies. 65 § 106 DGCL. 66 § 102(b)(6) DGCL. 67 § 141 DGCL. 68 §§ 201–202 DGCL. 69 § 102(a)(4) DGCL. ”71 Although shareholders rarely use this power, § 141 DGCL also gives shareholders the right to eliminate centralized management by vesting executive control in a body other than the board of directors, such as a council including all shareholders.
In the area of company law, German courts clearly break the mould of robotic obedience to the law’s letter that uninformed commentators on contemporary Civil Law would impose. 55 Indeed, as will be seen in the next chapter, the German High Federal Court went further than any US court has dared to tread in reading an entity theory of partnership into the Civil Code because of the impracticality of continuing to follow an aggregate theory. Some leading company law decisions were handed down with reference to the Limited Liability Companies Act (Gesetz betreffend die Gesellschaften mit beschränkter Haftung or GmbHG) rather than the Aktiengesetz and then applied to stock corporations by analogy.
101 See FSA Listing Rules, Rule 9 (Model Code, Nos. ), FSA Listing Rules, Rule 10. 102 Secs. 942 et seq. CA 2006 and Takeover Code. ). 103 Chapter X of the Insolvency Act 1986; Davis (2008: 77). 104 Armour (2005: 44). 1 Functional components of company law Approaching comparative company law 23 aspect of corporate law, with particular focus on the duties of directors and the rights of the minority shareholders to relief, which, despite the broad coverage of statutory and administrative rules, remains central to any study of UK company law.