Germany's Embrace of a Rescue Culture -- a Comparison Between the Approaches Taken in Germany, Canada and the United States

An increasing number of restructuring proceedings in both the United States and Canada end in the liquidation of the debtor company. This might prejudice the rescue culture approach which is deeply rooted in both countries bankruptcy laws. At the very least, it is the expression of different economic circumstances and of a different creditors' structure which has excited for a little over a decade.;This thesis gives an overview of the different approaches available in Germany, Canada and the United States to rescue a debtor and explains what exactly is meant by a rescue culture policy. Furthermore, it examines the extent to which each legislator has embraced the rescue culture approach. Finally, it looks at the reasons and consequences of the above mentioned current North-American trend and examines the extent to which these developments may influence the outcome of restructuring proceedings in Germany.