1.Bankruptcy reorganization system in the United States
According to the reorganization procedure of the US bankruptcy law, it is divided into the voluntary reorganization proposed by the debtor and the compulsory reorganization system proposed by the creditor. The conditions for the voluntary reorganization of the debtor and the conditions for the filing of the application are the same.As long as the debtor thinks he needs to be rectified and he wants to rectify it, he can apply. Therefore, the bankruptcy law of the United States has no special restrictions on the application of the debtor.
2.The bankruptcy reorganization system in Britain
The first chapter of the British bankruptcy law relates to the rescue and reconstruction of the company.One of the company's voluntary arrangements is similar to the debtor's voluntary reorganization.According to the provisions of the British bankruptcy law, the directors of the company can make recommendations to the company and the creditors of the company according to the provisions of the reorganization.In addition, the administrator and the liquidator can apply for reorganization. So the UK bankruptcy law has no specific restrictions on the application of the debtor.
3.French bankruptcy reorganization system
If the debtor fails to repay the matured debts with its disposable assets, the proceeding of judicial reorganization shall begin, and the application for this procedure shall be put forward within 15 days after the debtor has ceased payment in the preceding paragraph.In the French bankruptcy reorganization system, the debtor's request for reorganization is not subject to other conditions.
4..Bankruptcy reorganization system in Japan
In 1952, under the intervention of the occupying army, Japan, which was in the post war economic renaissance period, formulated the company rejuvenation law, basically transplanting the reorganization system in the U.S. Bankruptcy Law.In addition, in Japan can be used for the dilemma of enterprises and then built in the revival of the reconciliation and commercial law in the company to rectify the program