Conflict of Laws and International Finance
Sweet & Maxwell (Verlag)
978-1-84703-207-2 (ISBN)
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Examines conflict of law issues in international finance
* Gives practical guidance on the conflict of laws from the governing law of contracts to areas such as financial regulation, financial torts, trusts and insolvency
* Helps you decide which legal system to adopt and how to resolve issues
* Covers the governing law of contracts so you are clear of the basis on which international financial contracts should operate
* Explains jurisdiction over financial contracts so you can advise clients on areas including and enforcement of foreign judgments
* Looks in detail at conflict of laws for security interests and title finance so you are completely informed on these important areas
* Examines conflict of laws for financial torts and financial trusts
* Discusses the conflict of laws for regulation of international finance and regulatory jurisdiction making the application of the correct regulations simpler
* Provides coverage of sovereign immunity in the UK, US and EUas well as the recognition of states, state succession and international organisations so that you can quickly find out about these areas for your clients
* Includes special treatment of conflict of laws in insolvency giving you expert guidance on this potentially tricky area
Introduction. Part one # Governing law of contracts. Choice of law and Rome Convention 1980. Scope of governing law. Governing law: foreign currency obligations, exchange controls, embargoes. Governing law: attachments, amalgamations, interest, taxation. Expropriations. Part two # Jurisdiction over financial contracts. Judicial jurisdiction and financial contracts. European Judgments Regulation. Restrictions on judicial jurisdiction. Commentary on financial jurisdiction clauses. Arbitration and financial contracts. Enforcement of foreign judgments. Prejudgment attachments. Part three # Security Interests and Property. Governing law of security interests and other property transfers. Arrest and enforcement jurisdiction. Insolvency conflicts for security interests and property. Part four # Regulation, Torts and restitution in financial law. Regulatory jurisdiction and governing law. Governing law of prospectus liability and other financial torts. Governing law of restitution. Governing law of trusts in financial transactions. Part five # Sovereign immunity and state aspects. Principles of sovereign immunity. UK, US and EU immunity legislation. Recognition of states. State succession. International organisations. Part six # Insolvency conflict of laws. Insolvency conflict of laws: introduction and jurisdiction. Recognition of foreign insolvency stays and representatives. Applicable law of insolvency issues. EU Insolvency Regulation. Uncitral Model Law on Cross-Border
Insolvency and implementation.
| Erscheint lt. Verlag | 31.7.2007 |
|---|---|
| Zusatzinfo | Illustrations |
| Verlagsort | London |
| Sprache | englisch |
| Themenwelt | Recht / Steuern ► EU / Internationales Recht |
| Recht / Steuern ► Wirtschaftsrecht ► Bank- und Kapitalmarktrecht | |
| ISBN-10 | 1-84703-207-9 / 1847032079 |
| ISBN-13 | 978-1-84703-207-2 / 9781847032072 |
| Zustand | Neuware |
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