Property in Securities
A Comparative Study
By (author) Eva Micheler
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Property in Securities by Eva Micheler
Book DescriptionMicheler 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.
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Book DetailsISBN: 9780521832656
(228mm x 152mm x 25mm)
Imprint: Cambridge University Press
Publisher: Cambridge University Press
Publish Date: 28-Jun-2007
Country of Publication: United Kingdom
Books By Author Eva Micheler
Joint Ventures in English and German Law, Hardback (July 2000)» View all books by Eva Micheler
This collection examines and compares the legal framework of joint ventures between English and German companies.
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Author Biography - Eva Micheler
Senior Lecturer at the London School of Economics and a Universitatsprofessor at the University of Economics in Vienna.
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