harmonisation of insolvency law, has ignored the greater challenge that differences in political ideologies pose.The paper uses a … comparative analysis of the laws of France, Germany and England to ask whether the unique history of insolvency law makes it more …

where insolvency is impending according to the current uneven company-law framework and the harmonizing provisions drafted … directors' creditor-regarding duties where the business is nearing insolvency. Whilst they may theoretically constitute an … by enhanced directors' duties in the vicinity of insolvency. On the contrary, far from duplicating the remedies available …

This chapter deals with fundamental issues of corporate insolvency law. Particular attention is paid to the agency … structure of the chapter follows the issues as they arise in time in a corporate insolvency proceeding: objectives of insolvency … (corporate) insolvency laws. In terms of jurisdictions, the chapter mainly draws on the corporate insolvency laws in the US …

Certain insolvency law rules, like creditors' priorities and set-off rights, have a distributive impact on creditors … relevance and pose an obstacle to reforming the EU Insolvency Regulation. This paper will show the difficulty of reform by … model', under which companies can select the insolvency law they prefer. Although such a model would allow distressed firms …

The management of international insolvency proceedings and debt-restructuring operations constitutes a field in which … industry lies on the uniform regime that EU Law (specially the Regulation on Insolvency Proceedings) provides for this matter …