商品簡介
This work analyzes the fundamentals and special features of Canadian insolvency law in comparison to the Austrian legal system. It highlights key differences between Canada's common law system and Austria's continental European approach. The focus is on the constitutional distribution of competences, relevant legal sources, corporate forms and the role of procedural actors and creditors. Particular attention is paid to the opening of insolvency proceedings and the question of whether an obligation to file for insolvency, as in Austria, is also conceivable in Canada. Further topics include the law of collateral security, differences to the Austrian title and mode tradition, as well as Canadian avoidance law. Finally, restructuring instruments of the BIA and CCAA are presented and the fundamental differences between the two legal systems are summarized.
