@article{oai:chuo-u.repo.nii.ac.jp:00012084,
 author = {大杉, 謙一},
 issue = {1},
 journal = {中央ロー・ジャーナル},
 month = {Jun},
 note = {application/pdf, This article discusses corporation laws and securities regulations that govern merger-and-acquisition transactions in Japan, Germany, and the U.S. It also compares provisions to find how they differ. 
Japan and the United States regulate M&A transactions ex post, while the law in Germany does ex ante. The relative weakness of legal academics in Japan’s legislative process may be one reason for the difference. Another possible and compatible explanation is that differences result from ownership patterns in the three economies. Moreover, Japan’s Financial Services Agency’s respect for the need for M&A may have caused it to adopt a less rigorous approach in preparing securities regulation legislation.},
 pages = {21--46},
 title = {クロスボーダーM＆Aにおける株主保護  ―日本法・ドイツ法・アメリカ法を中心に―},
 volume = {16},
 year = {2019},
 yomi = {オオスギ, ケンイチ}
}