Cross Border Insolvency: Principles & Practice

This book approaches cross-border insolvency from the perspective of conflict of laws with a view to strengthening the understanding and practice of cross-border insolvency. The book analyses the whole corpus of cross-border insolvency regimes from three conflicts perspectives, namely:Set up a standing order and savei. jurisdiction to commence insolvency proceedings;ii. recognition and enforcement of foreign insolvency proceedings;iii. choice of law.This approach to cross-border insolvency allows the principles of cross borderinsolvency to be compared and contrasted across the wholecorpus.It thereby teases out the inconsistencies between the different regimes dealing with essentially the same cross-border issues. Approaching cross-border insolvency in this manner, so far not attempted by any other textbook, should help everyone interested in this area of the law appreciate that cross-border insolvency problems often find their solutions in the proper understanding of insolvency policy and principles.Cross-Border Insolvency features:EU Insolvency RegulationBrussels I RegulationUNCITRAL Model Law on Cross- Border InsolvencyCredit Institutions (Reorganisation and Winding Up)Regulations 2004Insurers (Reorganisation and Winding Up)Regulations 2004Insolvency Act 1986Foreign Judgments (Reciprocal Enforcement) Act 1933Administration of Justice Act 1920Common lawComparative analysis