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International Insolvency Law: National Laws and International Texts

International Insolvency Law: National Laws and International Texts

International Insolvency Law: National Laws and International Texts

Author: Elina Moustaira
Publisher: Springer-Verlag
ISBN: 9783030044497
Published In: January 2019
Format: Hardback
Jurisdiction: Switzerland ? Disclaimer:
Countri(es) stated herein are used as reference only

HKD 1,329.00

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Description
Contents

Details

This book presents problems that often arise in the context of international/cross-border insolvencies; analyzes and compares national legislations and jurisprudence; elucidates the solutions offered by international/regional instruments; and explores the differences in the implementation of these instruments by various countries and the consequences of these differences.

It examines in detail a number of famous and less famous cases tried by national courts, in which it became readily apparent that insolvency law remains one of the bastions of national law. In addition, the book discusses the notion of transplanting foreign [international] insolvency rules and especially the influence that US insolvency law has exerted on other countries' insolvency [and international insolvency] law. Far from adopting an unrealistically optimistic stance, it soberly examines the complications of cross-border insolvencies, while also presenting potential solutions.

Introduction

Insolvency - International Insolvency

Influences - Legal Transplants

European Union

UNCITRAL Model Law 1997

Protocols

Groups of Companies

Restructuring

Conclusions.

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