A SHIFTING PARADIGM OF EUROPEAN COMPANY LAW?
11 Colum. J. Eur. L. 219 (2005) Kubler, Friedrich. Professor of Law, University of Pennsylvania Law School; Professor Emeritus, University of Frankfurt. I. THE EUROPEAN COMPANY LAW REGIME A. The Basic Model Traditionally, company law on the European continent has been quite different from the structures which have evolved in the U.S. The various national systems differ in many ways, but there appears to exist a common pattern that shows its own distinct features. This pattern appears particularly obvious in Germany; thus I will use the German system as a starting point for my inquiry without always explaining how the […]