What is the common structure of the law of business corporations-or, as it would be put in the UK, company lawacross— national jurisdictions Although this question is rarely asked by corporate law scholars, it is critically important for the comparative investigation of corporate law. Recent scholar- e cor ship emphasizes the divergence among European, American, and Japanese cor- porations in corporate governance, share ownership, capital markets, and business culture. But, notwithstanding the very real differences across jurisdic- tions along these dimensions
