A Comparison of US, UK, and German Insolvency Codes
比较了美国、英国和德国的破产法，评估其效率，并分析了正式与非正式重组中债权人和股东的权益变化及破产成本。
This paper describes three insolvency codes, those of the United Kingdom (UK), Germany, and the United States (US) 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' reorganizations 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 accrued both to equityholders and different classes of creditors. Some evidence of the costs of bankruptcy is also provided for each country.