Cross-border Security and Insolvency: Cross-border Security & Insolv

Hardcover | March 1, 2001

EditorMichael Bridge, Robert Stevens

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This volume analyzes the legal and practical issues that arise in cross-border transactions involving the taking and enforcement of security over movable and intangible property. Having analyzed the domestic law of security in the UK, US, France and Germany, it then focuses upon the privateinternational law and insolvency law issues. Contributions come from leading legal, insolvency and banking specialists drawn from the relevant jurisdictions, providing a comparative perspective on each topic discussed. Coverage includes a focused, practical, case-study plus input from banking andinsolvency professionals.

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This volume analyzes the legal and practical issues that arise in cross-border transactions involving the taking and enforcement of security over movable and intangible property. Having analyzed the domestic law of security in the UK, US, France and Germany, it then focuses upon the privateinternational law and insolvency law issues. ...

Michael Bridge is at University of Nottingham. Robert Stevens is at Lady Margaret Hall, Oxford.

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Format:HardcoverDimensions:408 pages, 9.21 × 6.14 × 1.02 inPublished:March 1, 2001Publisher:Oxford University PressLanguage:English

The following ISBNs are associated with this title:

ISBN - 10:0198299214

ISBN - 13:9780198299219

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Table of Contents

Foreword by the Rt. Hon. the Lord Millett1. Robert Stevens: IntroductionPart 1 The Problem of Cross-border Security and Insolvency2. Lindsay J Town: A Banker's PerspectivePart 2 Security under Domestic Law3. Richard Calnan: Taking Security in England4. Richard F Broude: Secured Transactions in Personal Property in the United States5. Martin Gdanski: Taking Security in France6. Dr Burkhard Jakel: Outlines of Security Interests under German LawPart 3 Security in Private International Law7. Professor Michael Bridge: English Conflict Rules for Transfers of Movables: A Contract-Based Approach8. Professor Ulrich Drobnig: German Conflicts Rules on Security Interests in Movable Assets9. Professor Catherine Kessedjian: The Conflict of Laws Principles in French Law with Respect to Security Interests in Movable Assets10. Professor Charles W Mooney Jun: Extraterritorial Impact of Choice of Law Rules for Non-United States Debtors under Revised Uniform Commercial Code Article 9 and a New Proposal for International Harmonization11. Robert Stevens: The English Conflict of Laws RulesPart 4 Uniform Law12. Professor Sir Roy Goode: The UNIDROIT Mobile Equipment ConventionPart 5 Cross-Border Insolvency13. Mark Homan: An Insolvency Practitioner's Perspective14. Professor Ian Fletcher and Hamish Anderson: The Insolvency IssuesAppendicesAppendix 1The Colloquium Case StudyAppendix 2Article 9 of the Uniform Commercial Code (selected provisions)Appendix 3Council Regulation (EC) No 1346/2000 of 29 May 2000 on insolvency proceedingsAppendix 4UNIDROIT Convention on International Interests in Mobile EquipmentAppendix 5Protocol to the UNIDROIT Convention on International Interests in Mobile Equipment on Matters Specific to Aircraft Equipment

Editorial Reviews

`... situations in France, The United States and the United Kingdom have been particularly well dealt with. It is a useful reference work for the commercial lawyer who has any kind of international flavour to his or her practice.'New Law Journal, 3 Aug 2001