书目名称 | International Insolvency Law | 副标题 | National Laws and In | 编辑 | Elina Moustaira | 视频video | | 概述 | Explores the influences between nations’ insolvency laws.Analyzes international jurisdiction issues and stresses the problems of parallel insolvencies.Analyzes the complicated system that EC Regulatio | 图书封面 |  | 描述 | 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. | 出版日期 | Book 2019 | 关键词 | International insolvency; Influences; Legal transplants; Unification of laws; Par conditio (omnium) cred | 版次 | 1 | doi | https://doi.org/10.1007/978-3-030-04450-3 | isbn_ebook | 978-3-030-04450-3 | copyright | Springer Nature Switzerland AG 2019 |
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