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date: 27 January 2021

Abstract and Keywords

The concept of the corporation is not separable from the systems of incorporation and regulation that instantiate it. This is true of both the ‘American’ model of the corporation, with its dominant emphasis on shareholder rights (no matter how imperfectly those rights are protected), and of the ‘European’ model, with its attention on community interests, especially employment issues. The former is frequently attacked by Europeans for its neglect of the interests of key stakeholders, while the latter is attacked by Americans for its neglect of economic efficiency. This article shows why too much journalistic and academic debate has been wasted defending the American conception over the European and vice versa. Given the conceptual tools that both sides tend to employ defending their conceptions, the debate is irresolvable. It is, in effect, a puzzle with missing pieces.

Keywords: corporation, incorporation, shareholder rights, European model, stakeholders

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