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Maritime Cross-Border Insolvency: An Analysis for Germany, England & Wales and the USA

Maritime Cross-Border Insolvency: An Analysis for Germany, England & Wales and the USA

作者： Erik Goeretzlehner
出版商： Springer-Verlag
ISBN: 9783030117924
出版时间 May 2019
规格： Hardback
适应领域： Switzerland ? 免责申明：
Countri(es) stated herein are used as reference only

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This book provides an analysis and comparison of international insolvency rules, maritime laws and their inevitable intersection in maritime cross-border insolvencies. Until today, the on-going shipping crisis resulted in the insolvency of numerous shipping companies all over the world. The tensions arising between the legal systems of maritime and insolvency law, paired with conflicts of law in maritime insolvencies, are a major source of legal uncertainty and risk. In 2010, the Comité Maritime International installed an international working group on international maritime insolvencies and until today it is work in progress.

This book gives an overview on maritime insolvencies, with a focus on Germany, England & Wales and the USA, and assesses the chances of achieving meaningful harmonization in the complex scenarios, where ships as mobile assets add a further complication to international insolvency proceedings.
Introduction
Cross-border Insolvencies
The Maritime Industry and the Peculiarity of Maritime Liens
Maritime Cross-Border Insolvency and Harmonisation
Conclusion

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