Sino-us Corporate Governance Structure Is A Comparative Study

Corporate governance is a world-wide problem. Various countries have had many important achievements in theoretical research and practical exploration. It is a long-term for corporate governance to change and develop .According to the research of western scholars, it can be divided into two kinds: The Great Britain and American mode and The Germany and Japanese mode. It is a lot of difference between Chinese corporate governance and American corporate governance in the background and mechanism. Chinese corporate governance has gone through from the administration type to marketization, and formd the " three boards and four rights" structure. Such new corporate governance has played a positive role in overcoming the poor efficiency of the traditional structure. But seen from the reality, it has not formed the independent Board of directors to exercise decision and supervision function because the phenomenon of excessive concentration of stock, state-owned stock and inside control is serious. There is great difference between system design and actual operation. The American corporate governance has developed and reformed gradually. Through the development of more than one century, it has already formed the new classical idea of shareholder's sovereignty mode. The new reform of American corporate governance focuses on the improvement of the inside supervision mechanism and establishment of the outside supervision system. The advanced experience of America can help China to establish its own corporate governance mechanism.