Shareholder derivative litigation is a target of constant criticism within the United States (U.S.). Many scholars advocate for its abolition and others propose strict limitations on its use. If shareholder derivative litigation were universally disfavored, one would expect countries to be...

This article considers the tort choice of law rules in Canada and the United States – two highly internationalist societies with similar legal traditions but whose choice of law rules vary dramatically. The two jurisdictions are also known for their constant reference to international law in...