Cross-border Transactions of Intermediated Securities - A Comparative Analysis in Substantive Law and Private International Law

This work aims to analyse substantive and conflict of laws rules regarding intermediated securities in a comparative way. For this purpose, it examines major jurisdictions' rules for intermediated securities and the intermediated securities holding systems, such as the rules of the German, US, Korean, Japanese and Swiss systems, as well as the relevant EU regimes and initiatives. Above all, it analyses the two international instruments related to intermediated securities, i.e. the Geneva Securities Convention and the Hague Securities Convention. Through a functional comparative approach based upon legal traditions of the various jurisdictions, this book gives readers theoretical and practical information on intermediated securities and their national and international aspects.

Résumé

This work aims to analyse substantive and conflict of laws rules regarding intermediated securities in a comparative way. For this purpose, it examines major jurisdictions’ rules for intermediated securities and the intermediated securities holding systems, such as the rules of the German, US, Korean, Japanese and Swiss systems, as well as the relevant EU regimes and initiatives. Above all, it analyses the two international instruments related to intermediated securities, i.e. the Geneva Securities Convention and the Hague Securities Convention. Through a functional comparative approach based upon legal traditions of the various jurisdictions, this book gives readers theoretical and practical information on intermediated securities and their national and international aspects.

Détails du produit

• Auteurs: Changmin Chun
• Edition: Springer, Berlin
• Langues: Anglais
• Format d'édition: Livre Relié
• Sortie: 08.12.2011
• EAN: 9783642278525
• ISBN: 978-3-642-27852-5
• Pages: 504
• Dimensions: 159 mm x 36 mm x 239 mm
• Poids: 952 g
• Illustrations: XX, 504 p.
• Catégories: Livres de conseils > Droit, profession, finances > Impôts; Sciences sociales, droit, économie > Droit > Impôts; B, Business, Business and Management, International Law, Commercial law, Business & management, Private International Law, Civil Law, Business and Management, general, Law and Criminology, Financial Law/Fiscal Law, Conflict of Laws, Fiscal Law, comparative law, Management science, Private or civil law: general, Systems of law: civil codes / civil law, Public finance