Being precise about the two kinds of reverse veil piercing

I thought I was done mining Keith Paul Bishop's post on Curci Investments, LLC v. Baldwin, Cal. Ct. App. Case No. G052764 (Aug. 10, 2017), but one more minor point needs to be made. Keith writes:

As the name suggests, reverse veil piercing occurs when a third party outsider is able to reach corporate assets to satisfy claims against an individual shareholder. 

Well, yes, but ....

As Todd Henderson and I explained in our book Limited Liability: A Legal and Economic Analysis, there are two types of reverse veil piercing. One type might be called insider reverse veil piercing, in which a shareholder seeks to disregard the corporate entity. 

The other is so-called outsider reverse piercing, in which a personal creditor of the shareholder seeks to disregard the corporation’s separate legal existence to reach assets of the corporation to satisfy its claim.

Keith's definition only encompasses the latter.

This distinction is important, because in our view outsider reverse veil piercing is far more problematic:

Outsider reverse veil piercing effectively bypasses the usual method of collecting a judgment against a corporate shareholder, in which the creditor attaches the debtor’s shares in the corporation and not assets of the corporation. Unsecured creditors who relied on firm assets in lending to the corporation are thus disadvantaged. Similarly, if there are other shareholders, their interests are adversely affected if the corporation’s assets can be directly attached by the personal creditor of one shareholder. And, after all, the creditors of the shareholder-debtor can be satisfied by the debtor’s claim on the assets of the corporation indirectly, such as by taking the shares in settlement of the debt.