Limited liability in comparative perspective
Bibliographic record
Abstract
In this Chapter, we briefly look at the doctrine of veil piercing in several leading industrial nations. We observe limited liability everywhere in the developed world, from Canada to China. And, as we document, where limited liability goes, so too goes the doctrine of piercing the corporate veil. All the countries we survey permit courts to disregard the separate legal entity of corporations in a limited number of circumstances. Next, we briefly survey the types of limited-liability firms and doctrines for veil piercing in the United Kingdom, Canada, Australia, France, Germany, Japan, and China. We conclude that although the rules vary widely by name, doctrinal approach, and process, at the end of the day, most end up looking quite like their American equivalents. Courts rarely pierce, and when they do, it is mostly in an unprincipled way. Moreover, as in America, piercing is generally not done with an eye on creating the optimal incentives, but rather courts seem to be trying to achieve fairness or justice in ad hoc way in a particular case. The proxies for abuse of the corporate form that foreign courts use are similar to those used in the U.S.: disrespect for corporate formalities, unity of decision making, commingling of funds, and the like.
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.000 |
| Bibliometrics | 0.001 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.003 | 0.003 |
| Open science | 0.001 | 0.001 |
| Research integrity | 0.001 | 0.001 |
| Insufficient payload (model declined to judge) | 0.001 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; both teacher heads agree on what is shown here.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".