Comparative Research For Bankruptcy Legal System Of China And Foreign Countries

Bankruptcy appeared in certain stage of the society of merchandise . In the modern law system of all countries , the bankruptcy law all occupies a very important position.The bankruptcy law system can be traced back to the ancient Rome ages .Some foreign countries have developed a perfect bankruptcy law system with features of ages . Our current bankruptcy law system is out of date ,it is too brief and coarse and lacked of maneuverability . For our current bankruptcy law system to be perfect, in view of the author , we should not only study the legislation and jurisdiction of our own country ,but also draw lessons of the lawmaking experience of abroad.Because of space, this article only deals with bankruptcy capacity .bankruptcy reason, bankruptcy exemption, Creditor autonomy and Property administrator of Chinese and Foreign bankruptcy law .With the comparative method, in every part, the article first studies the abroad's principle and concrete provisions, then in correspondence of relevant provisions of our current law , makes the evaluation and gives the author's opinion to amend it.