Takeovers: English and American
对比英美公司治理体系，指出英国收购市场更活跃、监管更少，而美国因州政府主导的公司法政治力量压制了敌意收购。
Viewed against the backdrop of European company law generally, the UK and US systems of corporate governance are remarkably similar. However, there are several salient differences between the system, including the fact that the UK has a more robust and less regulated takeover market than the USA, while the USA is more permissive towards derivative litigation. This paper explains the differences as a function of politics. In the USA, where corporate law is dominated by state governments, the political forces aligned against hostile takeovers are quite potent, generating legislation and judicial decisions that have suppressed takeover activity. In the UK, with a more unitary system, the political forces play out differently, and the system accordingly generates rules more accommodating to unfriendly takeovers.