Abstract

Commenting on the British and the American system of corporate governance is a challenging task from a German perspective. As Prof. Bank and Prof. Cheffins outlined, the United Kingdom’s as well as the United States’ economies are dominated by public companies with a broad shareholder structure. However, the patterns of ownership and control vary around the world. Germany, for instance, can be seen as one of the countries where a different system emerged; even though the starting positions had substantial similarities within the 19th century

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