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2017
Abstract In the practice of insolvency law, the usual challenge is to work out the answer to a problem as a matter of general law and then to factor in the consequences of one or more of the parties being insolvent. In cross-border insolvency cases, this exercise can be made considerably more complicated by choice of law issues ...
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Abstract In the practice of insolvency law, the usual challenge is to work out the answer to a problem as a matter of general law and then to factor in the consequences of one or more of the parties being insolvent. In cross-border insolvency cases, this exercise can be made considerably more complicated by choice of law issues ...
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The Future of Cross-Border Insolvency
2018This book interrogates the current cross-border insolvency regime and sets out a pattern to improve its future. In recent decades, and especially since the global financial crisis, a number of important initiatives have focused on developing effective solutions for managing the insolvency of multinational enterprises and financial institutions.
Mevorach Irit
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Abstract This chapter details the key concepts surrounding cross-border insolvency law. It explains the relevant codifications and the underlying principles. The chapter discusses the issues revolving around insolvency proceedings with cross-border connotations, such as jurisdiction, applicable law, recognition, and administration of ...
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European Cross-Border Insolvency Law
2016Abstract This book provides a distilled and accessible analysis of the European cross-border insolvency law. With reference to the amended Insolvency Regulation (EIR) and related sources it examines the issues involved in intra-member state cross-border insolvency.
Bork, R, MANGANO, Renato
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2017
Abstract Chapter 5 is concerned with cross-border insolvency.
Sarah Paterson, Rafal Zakrzewski
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Abstract Chapter 5 is concerned with cross-border insolvency.
Sarah Paterson, Rafal Zakrzewski
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The American Journal of Comparative Law, 1990
In the United States, debtor-creditor relations involving, for example, contract and tort claims and property rights, are governed basically by the laws of the various states. However, state insolvency proceedings as such, e.g., receiverships, are relatively rare because the entire field of bankruptcy is comprehensively and exclusively regulated by the
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In the United States, debtor-creditor relations involving, for example, contract and tort claims and property rights, are governed basically by the laws of the various states. However, state insolvency proceedings as such, e.g., receiverships, are relatively rare because the entire field of bankruptcy is comprehensively and exclusively regulated by the
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Cross-Border Security And Insolvency
2001Abstract This volume analyzes the legal and practical issues that arise in cross-border transactions involving the taking and enforcement of security over movable and intangible property. Having analyzed the domestic law of security in the UK, US, France and Germany, it then focuses upon the private international law and insolvency law ...
Michael Bridge, Robert Stevens
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