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Property in Securities - A Comparative Study (Electronic book text)
Property in Securities - A Comparative Study (Electronic book text): Eva Micheler

Property in Securities - A Comparative Study (Electronic book text)

Eva Micheler

Series: Cambridge Studies in Corporate Law, 6

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Micheler analyses the German, Austrian and English law of securities, addressing the rules governing transfers of securities, including unauthorised transfers, equities arising out of defective issues, and the holding of securities through intermediaries. The book presents an account of the current English, German and Austrian regimes. It has been written with a view to explaining the German and Austrian regime to readers with a common law background and to explaining the English regime to readers with a civil law background. Micheler also aims to determine whether globalisation will cause the two different approaches to converge. It concludes that the respective rules in all three jurisdictions have historically evolved consistently with incumbent legal doctrine. This pattern of change is likely to continue. Convergence will occur on a functional rather than doctrinal level. Moreover, recent reform initiatives advanced by the UNIDROIT and the EU will lead to functional rather than doctrinal convergence.

General

Imprint: Cambridge University Press (Virtual Publishing)
Country of origin: United Kingdom
Series: Cambridge Studies in Corporate Law, 6
First published: 2007
Authors: Eva Micheler
Format: Electronic book text
ISBN-13: 978-0-511-29113-5
Categories: Books > Law > Jurisprudence & general issues > Comparative law
Books > Law > Laws of other jurisdictions & general law > General
LSN: 0-511-29113-2
Barcode: 9780511291135

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