Abstract:

The national models of insolvency regulations in the US, Germany, France and Russia are analysed in the article. The advantages and disadvantages of insolvency regulations aimed at protecting the interests of a debtor (USA, France) and focused on protecting the interests of creditors (Germany) are revealed in the research. The article has proved the feasibility of macroeconomic focus of the Russian model of insolvency due to the objective need to preserve and expand the productive capacity of the national economy. The mechanisms of foreign insolvency systems applicable to the Russian practice are obtained.