Comparative Corporate Law

This book studies the systems regulating the relationships between the primary participants in a corporation — shareholders, officers, directors — and the state in the most important commercial regions of the world today.

The book focuses on presenting differences in a number of significant areas of corporate governance, specifically, the formal sources of law, and the approach as manifest in actual regulation. The book also explores the ways different systems interact by looking at ways corporations created in one state are recognized and permitted to function in other states.

Comparative Corporate Law studies the differences between systems to determine the extent to which those differences are superficial, thus masking a common core of norms, or evidence of the existence of incompatible views. The ultimate aim is to understand the ways in which systems adjust to the existence of other, sometimes competitive, systems of corporate governance.

In an era of global trade, the power of harmonization, emulation, penetration, convergence, and separation, is inseparably linked to the comparative study of governance systems. Backer provides the framework for that study with clarity and attention to detail.

A teacher's manual is forthcoming.