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KEYWORDS: CLASSIFICATIONS * ENTITY * HYBRIDS * PARTNERSHIPS * CORPORATIONS * COMPARABILITY
ABSTRACT
After reviewing the Canadian and UK jurisprudence endorsing the factual use of foreign commercial law when characterizing foreign business associations, this article considers some of the problems in applying this two-step approach and concludes that conventional tools such as the use of the composite concept of legal personality (or lack of it) yield uncertain results. In fact, one fundamental thesis of the article is that when comparing...