Jurisdiction issues
It happens with increasing frequency that aUNCITRAL
Chapter 15 incorporates the Model Law on Cross Border Insolvency drafted by theDiscretionary assistance
Whether the US courts will extend the "additional assistance" sought in connection with a foreign proceeding under Chapter 15 is a matter of discretion. The main consideration US courts will take into account in making this decision is whether the laws of the foreign jurisdiction violate the laws or public policy of the United States and whether the foreign courts conduct their proceedings according to basic rules of procedural fairness. Among other factors the US courts will consider is how the foreign jurisdiction treatsOriginal Chapter 15 (1978–1984)
The original 1978 Bankruptcy Code had a different Chapter 15 dealing with theExternal links