| This article explores the corporate governance in the developed countries and China from a comparative perspective. Following detailed analysis in principal-agent model at the core of corporate governance theories, this article examines the dispersion-to-concentration ownership span to explore the concentration degree with influence on the majority/minority ownership construct and the shareholder/manager conflicts. This article compares the positive and negative edges of concentrated shareholding with empirical analysis of corporate practice in Canada, the U.S., and China, and finds the different roles of institutional shareholders in various countries. Two-tier agency model is another way to enhance corporate governance. Compared with the vertical two-tier construct with the vanguard of Germany, this article illustrates that the supervisory board in China is in horizontal position paralleled to the board of directors, which loses its original supervising purpose in corporate governance. This article finally explores the independent director system. The independent director has already demonstrated its positive influence upon corporate governance in developed countries, while in China, this system still lacks legal protection and is not effective as expected. |
