The goal of this thesis is to discover differences in regulation of sales contracts in Anglo-American and Continental legal system. The thesis looks for and compares distinctions between regulation in Uniform Commerical Code adopted in most of the states of the USA that represents the Anglo-American System, and Louisiana Civil Code which was chosen by the author thanks to its strong link to french Code Civil as a representative of Continental System. The author analyzes differences in definition of sales contract, the process of its formation, she looks at the question of passage of title and passage of risk, furthermore she deals with rights and obligations of seller and buyer. Eventually, she summarizes the distinctions found.
| Identifer | oai:union.ndltd.org:nusl.cz/oai:invenio.nusl.cz:75198 |
| Date | January 2010 |
| Creators | Dufková, Marie |
| Contributors | Boháček, Martin, Švarc, Zbyněk |
| Publisher | Vysoká škola ekonomická v Praze |
| Source Sets | Czech ETDs |
| Language | Czech |
| Detected Language | English |
| Type | info:eu-repo/semantics/masterThesis |
| Rights | info:eu-repo/semantics/restrictedAccess |
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