The GmbH in Germany, the SARL in France, and the British "private company" may be considered counterparts to the close corporation in the United States. The theories of organization of these foreign concerns are a combination of contractual norms, partnership principles, and some corporation law principles. This Article analyzes the three types of corporate organization in terms of development, structure, and management. The Article concludes with a brief comparison of the three concerns and their "public" company counterparts.
Mark R. von Sternberg,
The Close Corporation's Counterparts in France, Germany, and the United Kingdom: A Comparative Study,
5 Hastings Int'l & Comp. L. Rev. 291
Available at: https://repository.uchastings.edu/hastings_international_comparative_law_review/vol5/iss2/2