Open Access. Powered by Scholars. Published by Universities.®
Bankruptcy Law; International Law; Insolvency Law; UK; US; Rubin; HIH Casualty; Cambridge Gas; Lord Collins; Lord Hoffman; UNCITRAL; UNCITRAL Working Group V; Bankruptcy; Insolvency; Cross-Border Insolvency; UNCITRAL Model Law on Cross-Border Insolvency; MLCBI; ML-CBI; UNCITRAL Model Law of the Recognition and Enforcement of Insolvency-Related Judgments; MLIRJ; ML-IRJ; UK Supreme Court; Soft Law; Model Law; Universalism; Modified Universalism; Cooperative Territorialism; Territorialism; Comity; International Bankruptcy; International Insolvency; Transnational Bankruptcy; Transnational Insolvency; Dicey Rule; Dicey’s Rule; Recognition; Relief; Cooperation; Access; Insolvency Judgment; Insolvency Proceeding; Bankruptcy Proceeding
Articles 1 - 1 of 1
Full-Text Articles in Law
Please Recognize Me: The United Kingdom Should Enact The Uncitral Model Lawon Recognition And Enforcement Of Insolvency-Related Judgments, John A. Churchill Jr.
Please Recognize Me: The United Kingdom Should Enact The Uncitral Model Lawon Recognition And Enforcement Of Insolvency-Related Judgments, John A. Churchill Jr.
Brooklyn Journal of International Law
Since 1995, the United Nations Commission on International Trade Law (UNCITRAL), has been developing tools to meet the challenges of having different insolvency laws managing a single cross-border insolvency. By 1997, UNCITRAL’s Working Group V completed the Model Law on Cross-Border Insolvency. By September 2020, the original model law has been adopted by 48 countries. In Rubin v. Eurofinance SA, the U.K. Supreme Court cited a lack of authority to recognize a U.S. insolvency-related judgment in the Model Law on Cross-Border Insolvency. As a result of this decision, UNCITRAL’s Working Group V developed the Model Law on Recognition and Enforcement …