Dagmar Eberle

Private interests and the EU-US dispute on audit regulation: The role of the European accounting profession

ABSTRACT Taking the European audit profession as a case study, our paper explores the role of private actors in transatlantic regulatory relations and transnational regulatory harmonization more generally. In the early twenty-first century, both the US and the EU tightened the regulation of auditors. Due to its extraterritorial effects, the US reform legislation sparked a transatlantic conflict. Seeking mutual recognition of the respective auditor oversight systems, the European Commission endeavored to bring the European regulatory regime closer to the new US model. During the reforms of EU audit regulation, the profession, together with member states, successfully resisted a far-reaching convergence of European regulation to the US model of independent oversight, thus impeding the resolution of the transatlantic conflict. We argue that the professions defense of the traditional model of European audit regulation results from two intertwined aspects: the professions interest in keeping a share of power in the regulatory regime and its institutional embeddedness in distinct national and regional regulatory and market structures. In concluding, we discuss the implications of our findings for the relevant international and comparative political economy literature.

Varieties of Change in German Capitalism: Transforming the Rules of Corporate Control

Whether distinct national ‘varieties of capitalism’ will survive in an increasingly globalising economy has become one of the most hotly debated issues in comparative political economy since the early 1990s. The major question in the academic debate is whether the institutional configurations of national political economies are increasingly converging on the market-oriented Anglo-Saxon model, whether the different varieties, in particular the continental European model of coordinated (‘Rhenish’) capitalism, will continue to evolve in path-dependent ways, or whether a growing ‘hybridisation’ of domestic institutional frameworks will occur. The latter term indicates that processes of institutional change may result in a melange of old and new, Anglo-Saxon and continental European elements. Our article seeks to enrich the debate on the ‘hybridisation’ of the German corporate governance system in both an empirical and a theoretical sense. Empirically, we are focusing on the rules which shape the distribution of influence and control over company policy among different groups of stakeholders. We perceive German corporate governance regulation as an institutional element of Germany’s coordinated capitalism. We assume that conflicts over the design of the regulatory regime suggest conclusions about the willingness of important actors to defend or reform existing structures. A national system of corporate governance regulation can be described as comprising three dimensions of corporate control. First, internal corporate governance mechanisms operate within the institutional framework of the firm. Within the corporation, the board of directors constitutes the main device for monitoring management. Second, external control is exercised by market forces and outside actors. The main external control mechanism is the capital market in the form of the market for corporate control. Third, located at the interface between internal and external corporate governance, between supplying information about the financial situation of a company to corporate insiders and to outside investors, is the accounting system. National corporate governance systems differ with New Political Economy, Vol. 13, No. 4, December 2008

On the Road to Anglo-Saxon Capitalism? German Corporate Governance Regulation between Market and Multilevel Governance

Financial internationalization and European regulatory harmonization put the German corporate governance regime under pressure to move towards a market-oriented, Anglo-Saxon model. While International Political Economy approaches expect Anglo-Saxon standards to spread across national borders, Comparative Political Economy predicts persistent diversity. In our paper, we trace the patterns and driving forces of change in two areas of corporate governance regulation, namely internal governance and accounting. In accounting, processes of multilevel coordination entailed a high degree of convergence towards Anglo-Saxon standards and institutions. A much greater stability of the domestic institutional framework can be seen in the case of internal governance. While political economy approaches offer important insights for analyzing these changes, both fail to account for the different patterns of convergence and divergence in the two cases. Therefore, we argue in favor of a policy analysis perspective to capture the sectorally distinct interplay of forces that shape the processes of regulatory change.

Mission Accomplished? A Comparative Exploration of Conservatism in the United States and Canada

When analyzing institutions and events in the “New World,” observers from the “Old World” have rarely been motivated just by curiosity. In the aftermath of the French Revolution, both liberals and conservatives tried to paint a picture of the United States that was supportive of their own position in the domestic debates (von Beyme 1986: 25ff). Alexis de Tocqueville explicitly stated in the foreword of his seminal work on “Democracy in America” that his interest in the United States arose from his desire to seek “the image of democracy itself, with its inclinations, its character, its prejudices, and its passions, in order to learn what we have to fear or to hope from its progress” (de Tocqueville 1956: 36). Thus, the political instrumentalization of America, so pervasive in the current public discourse in Europe, is not a new phenomenon. Ever since the birth of the American nation, Europeans have tended to project their highest hopes or worst fears onto the “New World.”

Kommunikationspolitik in Kanada — politische Steuerung zwischen Protektionismus und Wettbewerb

Kaum ein Politikfeld war in der jungsten Vergangenheit vergleichbaren technologischen Innovationsschuben ausgesetzt wie die Kommunikationspolitik. Tempo und Qualitat der Neuerungen lassen den Bereich als geradezu pradestiniert erscheinen fur die Analyse von Veranderungen der politischen Steuerung, zumal sich innerhalb des Policy-Sektors die vergleichende Untersuchung zweier Falle anbietet — einmal der Individualkommunikation (Telekommunikation), zum anderen der Massenkommunikation (Radio und Fernsehen). Die Frage nach Verlauf und Ausmas des steuerungspolitischen Wandels erhalt besonderen Reiz in einem nationalen Kontext, der eine sehr spezifische, von beachtlicher Kontinuitat der Problemdefinitionen und Antworten bestimmte Traditionslinie im staatlichen Umgang mit Kommunikationstechnologien ausgebildet hat.

Looking Back: The Emergence of Right-Wing Populist Parties in the Canadian West and their Performance in Government

Throughout the 20th century, structural changes to the Canadian party system generally originated in the West. The western provinces have served as a stage for the emergence of third parties like the CCF and Social Credit in the 1930s (Schultze 1997: 286). In the late 1980s and 1990s, the re-enactment of that play brought a new contender to federal politics, which fundamentally altered the nature of Canadian conservatism. The Reform Party, now the Canadian Alliance, superseded the venerable Progressive Conservative Party as main force of the political right and propelled an ideological shift in the direction of neo-conservatism.