It is not surprising that the problems of choice of law and international group insolvency have
not been sufficiently addressed during the initial development of cross-border insolvency …

This Article explores the potential content and the feasibility of a set of harmonized choice-of-
law rules that would apply in insolvency proceedings. For brevity's sake, the Article refers to …

The first two decades of law reform related to cross-border bankruptcy are the paired story of
the UNCITRAL Model Law (Chapter 15 in the United States) and the EU Insolvency …

This Article proposes a new classification of international texts for the purposes of
interpretation and an" international interpretive rule" to be applied to those found to be" …

The law relating to cross-border insolvency is largely founded on the concept of
universalism, which requires all claims against the insolvent debtor to be marshaled …

Like an adolescent struggling with clothes that no longer fit, the growing field of international
insolvency has not so far put aside the old notion that local priorities must always be applied …

In this time of relative prosperity, large multinational companies are filing insolvency
proceedings all over the world.'Restructuring is now part of the daily routine of global …

This book compares the two golden ages of private international law (PIL): the first is the era
of Story and Savigny in the nineteenth century, while the second comprises the last fifty …

With the growth of international business and the rise of companies with subsidiaries around
the world, the question of where a company should file bankruptcy proceedings has become …

The insolvency of multinational corporate groups creates a compelling challenge to the
commercial world. As many medium and large-sized companies are multinational …