Cross-border security and insolvency / edited by Michael Bridge and Robert Stevens
Imprint
Oxford [England] ; New York : Oxford University Press, 2001
Descript
xl, 367 p. ; 24 cm
CONTENT
The Problem of cross-border security and insolvency: A Banker's perspective -- Security under domestic law: Taking security in England -- Secured transactions in personal property in the United States -- Taking security in France -- Outline of security interests under German law -- English conflict rules for transfer of movables: a contract-based approach? -- German conflicts rules on security interests in movable assets -- The Conflict of laws principles in French law with respect to security in movable assets -- Extraterritorial impact of choice of law rules for Non-United States debtors under revised uniform commercial code article 3 and a new proposal for international harmonization -- The English conflict of laws rules -- Uniform law: The UNIDROIT mobile equipment convention -- Cross-border insolvency: An Insolvency practitioner's perspective -- The Insolvency issues