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The Overseas Dimension: What Can Canada and the United States Learn from the United Kingdom
| Content Provider | Semantic Scholar |
|---|---|
| Author | Adler, Michael |
| Copyright Year | 1999 |
| Abstract | The United States and, to a slightly lesser extent, Canada have come to regard personal bankruptcy as a routine method of discharging debts, enabling the debtor to make a fresh start. By contrast, in the United Kingdom, bankruptcy is still seen as a remedy of last resort, and creditors may retain the right to enforce debts. The difference in approach is due to the fact that the United States and Canada have traditionally given priority to risk taking over security, while the United Kingdom has continued to give priority to security over risk taking. However, the British government's enthusiasm for flexible labour markets and entrepreneurship suggests that this may be about to change. While many people in the United States are having second thoughts about their liberal approach to bankruptcy, and the American government is coming under intense pressure from the credit industry to make it harder for people to protect their assets, the British government has recently set in train a review of the legal and social framework of bankruptcy to see whether Britain can learn from the American experience. This article is available in Osgoode Hall Law Journal: http://digitalcommons.osgoode.yorku.ca/ohlj/vol37/iss1/18 THE OVERSEAS DIMENSION: WHAT CAN CANADA AND THE UNITED STATES LEARN FROM THE UNITED KINGDOM?© |
| Starting Page | 415 |
| Ending Page | 425 |
| Page Count | 11 |
| File Format | PDF HTM / HTML |
| Volume Number | 37 |
| Alternate Webpage(s) | https://digitalcommons.osgoode.yorku.ca/cgi/viewcontent.cgi?article=1544&context=ohlj |
| Language | English |
| Access Restriction | Open |
| Content Type | Text |
| Resource Type | Article |
