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| Tekijä: | Franks, J. R. Nyborg, K. G. Torous, W. N. |
| Otsikko: | A comparison of US, UK, and German insolvency codes |
| Lehti: | Financial Management
1996 : AUTUMN, VOL. 25:3, p. 86-101 |
| Asiasana: | CORPORATE SOLVENCY BANKRUPTCY LAW |
| Kieli: | eng |
| Tiivistelmä: | This paper describes three insolvency codes, those of the United Kingdom, Germany, and the United States and compares their efficiency against a number of benchmarks. These codes have been chosen because they cover a broad spectrum of debtor- and creditor-oriented insolvency procedures. The paper also compares the plans of distressed firms' reorganiations both within and outside the formal bankruptcy process, including the size of write downs and creditors' claims and the deviations from absolute priority which have accured both to equityholders and different classes of creditors. Some evidence of the costs of bankruptcy is also provided for each country. |
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