Discussion: Similarities and Differences in Conceptions between Australia, Hong Kong and the United States

2016 ◽  
pp. 163-178
Author(s):  
Matthew Conaglen

This chapter examines the principles of fiduciary doctrine that are found in contemporary common law systems. More specifically, it considers the current similarities and differences between various jurisdictions such as England, Australia, Canada, and the United States. The similarities focus on the duties of loyalty, care and skill, and good faith, as well as when fiduciary duties arise and the kinds of interests that are protected by recognition of fiduciary relationships. The chapter also discusses the issue of differences between various jurisdictions with regard to the duty of care and skill before concluding with an analysis of differences between remedies that are made available in the various contemporary common law jurisdictions when a breach of fiduciary duty arises. It shows that the regulation of fiduciaries appears to be reasonably consistent across common law jurisdictions and across various types of actors, even as such actors are expected to meet differing standards of care. Statute plays a key role in the regulation of various kinds of fiduciary actors, especially corporate directors.


Author(s):  
Peter Westwood

Abstract This article describes the evolution of inclusive education in Hong Kong, moving from segregation via integration to inclusion. The outside influence of education policies and trends from Britain, Australia, and the United States are identified, and the current situation is described. In particular, obstacles that are encountered on the route to inclusion are compared with those found in other countries. These obstacles include large class size, teachers’ often negative attitudes, parents’ expectations, teachers’ lack of expertise for adapting the curriculum and for providing differentiated teaching, and ongoing conflicts between the notion of ‘inclusive schooling for all’ and the ‘academic standards agenda’.


2020 ◽  
Vol 15 (2) ◽  
pp. 121-126
Author(s):  
Takisha Durm

PurposeThe Girl Who Buried Her Dreams in a Can, written by Dr Tererai, profiles a cultural, yet global experience of the power of believing in one's dream. Through this study of the similarities and differences of how children in the United States and abroad live and dream of a better life, this lesson seeks to enhance students' understandings of the power and authority they possess to effect change not only within their own lives but also in the lives of countless others in world. After reading the text, students will work to create vision boards illustrating their plans to effect change within their homes, schools, communities, states or countries. They will present their plans to their peers. To culminate the lesson, the students will bury their dreams in can and collectively decide on a future date to revisit the can to determine how far they have progressed in accomplishing their goals.Design/methodology/approachThis is an elementary grades 3–6 lesson plan. There was no research design/methodology/approach included.FindingsAs this is a lesson plan and no actual research was represented, there are no findings.Originality/valueThis is an original lesson plan completed by the first author Takisha Durm.


1997 ◽  
Vol 91 (3) ◽  
pp. 493-517
Author(s):  
Marian Nash (Leich)

On March 3,1997, President William J. Clinton transmitted to the Senate for its advice and consent to ratification as a treaty the Agreement Between the Government of the United States of America and the Government of Hong Kong for the Surrender of Fugitive Offenders, signed at Hong Kong on December 20,1996. In his letter of transmittal, President Clinton pointed out that, upon its entry into force, the Agreement would “enhance cooperation between the law enforcement communities of the United States and Hong Kong, and … provide a framework and basic protections for extraditions after the reversion of Hong Kong to the sovereignty of the People’s Republic of China on July 1, 1997.” The President continued: Given the absence of an extradition treaty with the People’s Republic of China, this Treaty would provide the means to continue an extradition relationship with Hong Kong after reversion and avoid a gap in law enforcement. It will thereby make a significant contribution to international law enforcement efforts.The provisions of this Agreement follow generally the form and content of extradition treaties recently concluded by the United States. In addition, the Agreement contains several provisions specially designed in light of the particular status of Hong Kong. The Agreement’s basic protections for fugitives are also made expressly applicable to fugitives surrendered by the two parties before the new treaty enters into force.


2021 ◽  
Vol 18 (3) ◽  
pp. 464-516
Author(s):  
Harald Baum ◽  
Toshiaki Yamanaka

Abstract This article studies the protection of retail and professional investors when financial products are sold or when investment advice is given. To this end, it clarifies the similarities and differences in the legal setting governing investment services firms in Germany and Japan, with a particular focus on a) the persons to be protected, b) information to be provided and c) private enforcement. Although regulatory structures are largely divergent in these two jurisdictions, the legal situation converges in several important points in relation to lawmaking in the European Union and the United States. Those convergences appear informative for the development of laws in jurisdictions other than Germany and Japan.


2000 ◽  
Vol 6 (2-3) ◽  
pp. 514-516
Author(s):  
O. Al Imam ◽  
A. Suleiman ◽  
S. Khuleifat

Splenic lengths in 184 normal Jordanian children were measured through the hilum by ultrasound and compared with data from Hong Kong and the United States of America. The spleen to left kidney ratio was calculated to determine whether it was constant and to establish a ratio above which splenomegaly can be diagnosed. Up to age 15 years, little variation in splenic length was observed, but over 15 years splenic length was slightly lower in Jordanian males. Spleen to left kidney ratio was constant at around 1; splenomegaly is highly probable in ratios >/= 1.25


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