Insolvency in private international law :national and international approaches
- 作者: Fletcher, Ian F.
- 出版: Oxford : Clarendon Press 1999.
- 稽核項: 1 online resource (lxvii, 465 pages).
- 叢書名: Oxford monographs in private international law
- 標題: LAW Conflict of Laws. , Faillite. , Conflict of laws , Faillite (Droit international privé) , Electronic books. , Droit international privé Faillite. , Etudes comparatives. , Faillite , Droit international privé , Conflict of Laws. , Faillite Etudes comparatives. , Bankruptcy. , LAW , Conflict of laws Bankruptcy.
- ISBN: 019825864X , 9780198258643
- ISBN: 019825864X
- 試查全文@TNUA:
- 附註: Includes bibliographical references (pages 454-455) and index. PART I-- INTERNATIONAL INSOLVENCY: NATIONAL APPROACHES: Theory and Principle in Cross-Border Insolvency -- Insolvency of Individuals -- Insolvency of Companies -- Judicial Assistance in Cross-Border Insolvencies: Current Provisions under National Law -- PART II-- INTERNATIONAL REGULATION OF INTERNATIONAL INSOLVENCY: Latin America and Scandinavia -- The European Union Convention on Insolvency Proceedings -- Council of Europe Convention of Istanbul, 5 June 1990 -- A Global Initiative: UNCITRAL Model Law on Cross-Border Insolvency -- Conclusion: Achievements, Trends and Prospects
- 摘要: This book deals with the problems generated by those cases of insolvency (either of an individual or of a company) involving more than one system of law, that bring into operation the principles and methods of private international law. The author provides guidance on the ways in which workable solutions to practical problems can be achieved using national and international remedies now available, including assistance available from foreign courts. Both English and international law is covered in detail, including the EC Regulation on Insolvency Proceedings, in force throughout the UK since May 2002, and the UNCITRAL Model Law on Cross-Border Insolvency, which is due for enactment in the UK. -- Provided by publisher
- 電子資源: https://dbs.tnua.edu.tw/login?url=https://search.ebscohost.com/login.aspx?direct=true&scope=site&db=nlebk&AN=18323
- 系統號: 005286036
- 資料類型: 電子書
- 讀者標籤: 需登入
- 引用網址: 複製連結
This book provides a detailed analysis of the conceptual and practical problems posed by the increasingly common phenomenon of cross-border insolvency, both in respect of individuals and companies. In Part I of the book the author considers how such problems are approached and resolved under national legal regimes, comparing the English common law approach with those of other jurisdictions such as Australia, Canada and the USA. Part II analyses the regional and international agreements and conventions that have been under negotiation in response to the special difficulties imposed by multi -jurisdictional insolvencies, such as the E.U. Insolvency Convention and the UNCITRAL model law on cross-border insolvency. The book will appeal equally to insolvency specialists and to international company and commercial lawyers more generally. The aim of the Oxford Monographs in Private International Law series, edited by Peter Carter QC, is to publish works of high quality and originality in a number of important areas of private international law. The series in intended for both scholarly and practitioner readers.
來源: Google Book
來源: Google Book
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