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Zusatztext ... situations in France, The United States and the United Kingdom have been particularly well dealt with. It is a useful reference work for the commercial lawyer who has any kind of international flavour to his or her practice. Klappentext This volume analyzes the legal and practical issues that arise in cross-border transactions involving the taking and enforcement of security over movable and intangible property. It includes private international law and insolvency law issues. Contributions come from leading legal, insolvency and banking specialists drawn from the UK, France, Germany and the US, providing a comparative perspective on each topic discussed. Zusammenfassung This volume analyzes the legal and practical issues that arise in cross-border transactions involving the taking and enforcement of security over movable and intangible property. Having analyzed the domestic law of security in the UK, US, France and Germany, it then focuses upon the private international law and insolvency law issues. Contributions come from leading legal, insolvency and banking specialists drawn from the relevant jurisdictions, providing a comparative perspective on each topic discussed. Coverage includes a focused, practical, case-study plus input from banking and insolvency professionals. Inhaltsverzeichnis Foreword by the Rt. Hon. the Lord Millett 1: Robert Stevens: Introduction Part 1 The Problem of Cross-border Security and Insolvency Part 2 Security under Domestic Law 4: Richard F Broude: Secured Transactions in Personal Property in the United States 5: Martin Gdanski: Taking Security in France 6: Dr Burkhard Jäkel: Outlines of Security Interests under German Law Part 3 Security in Private International Law 8: Professor Ulrich Drobnig: German Conflicts Rules on Security Interests in Movable Assets 9: Professor Catherine Kessedjian: The Conflict of Laws Principles in French Law with Respect to Security Interests in Movable Assets 10: Professor Charles W Mooney Jun: Extraterritorial Impact of Choice of Law Rules for Non-United States Debtors under Revised Uniform Commercial Code Article 9 and a New Proposal for International Harmonization 11: Robert Stevens: The English Conflict of Laws Rules Part 4 Uniform Law Part 5 Cross-Border Insolvency 14: Professor Ian Fletcher and Hamish Anderson: The Insolvency Issues Appendices Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 ...
