Download or read book Japanese and European Private International Law in Comparative Perspective written by Jürgen Basedow and published by Mohr Siebeck. This book was released on 2008 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt: The idea of national codification is advancing on a global scale in conflict of laws. A large number of legislative projects dealing with codifying and modernizing private international law, both on the national and the supranational level, have been launched in the past few years. Among such recent initiatives, the advances taken by the European and the Japanese legislators are particularly reflecting these developments. On January 1, 2007, the new Japanese 'Act on General Rules for Application of Laws' entered into force replacing the outdated conflict of laws statute of 1898. This major reform finds its parallels in the current efforts of the European Union to create a modern private international law regime for its member states.This volume presents the first comprehensive analysis of the new Japanese private international law available in any western language and contrasts it with corresponding European developments. Most of the contributors from Japan are scholars who were actively involved in and responsible for preparing the new Act. All of them are renowned experts in the field of private international law. Leading European experts in the conflict of laws supplement the Japanese analyses with comparative contributions reflecting the pertinent discussion of parallel endeavours in the EU. To guarantee better understanding, English translations of both the present and the former Japanese statutes have been added.
Download or read book Assignment in European Private International Law written by Axel Flessner and published by sellier. european law publ.. This book was released on 2006 with total page 143 pages. Available in PDF, EPUB and Kindle. Book excerpt: The assignment of contractual rights is of immense importance for the world of business and finance. Never before have assignments taken place on such a large scale as is the case in the contemporary securitisation market. Many receivables-based financial transactions, such as securitisations, are cross-border transactions. It is therefore often crucial to determine which law governs the proprietary aspects of assignment. The European Commission has, in its "proposal for a regulation on the law applicable to contractual obligations," formulated a new conflict rule referring the enforceability of an assignment against third parties to the law of the assignor's residence. This book demonstrates how the solution which has been adopted by the Commission is inadequate for receivables-based cross-border transactions. The authors argue that a cross-border assignment should, instead, be governed by the law chosen by the assignor and the assignee and, in the absence of a choice, by the law applicable to the assigned claim. The most important policy behind the Commission's conflict rule, i.e. that the assignor's creditors should be able to look to the assignor's law for registration requirements, can be realized in subtler ways, in particular by means of a special conflict rule for public filing systems. The Annexes contain the full texts of the Commission's Proposal, the UN Convention on the Assignment of Receivables, and Chapter 11 of the Principles of European Contract Law (Assignment of Claims).
Download or read book Research Handbook on EU Private International Law written by Peter Stone and published by . This book was released on 2017-05-26 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt: The harmonisation of private international law in Europe has advanced rapidly since the entry into force of the Treaty of Amsterdam. Most aspects of private international law are now governed or at least affected by EU legislation, and there is a substantial and growing body of case-law from the European Court as well as the courts of the Member States. This timely Handbook addresses key questions and problems that currently exist in the rules of private international law laid down by European Union regulations. Bringing together perspectives from both civil law and common law traditions, the book mainly considers issues relating to the Brussels I Regulation on civil jurisdiction and judgments, and to the Rome I and II Regulations on choice of law in respect of contractual or non-contractual obligations. Weaknesses in the current law are identified, and suggestions are made for possible improvements. The expert contributors focus on currently relevant problems including some issues which have tended to be neglected.Academics, law students and public officials interested in private international law will find this Handbook to be a valuable resource. Both practising lawyers and commercial lobbyists will also find many useful insights.
Download or read book Boundaries of European private international law written by Jean-Sylvestre Bergé and published by Emile Bruylant. This book was released on 2015 with total page 718 pages. Available in PDF, EPUB and Kindle. Book excerpt: L’existence d’un droit international privé européen n’est plus à démontrer. Les développements considérables auxquels il donne lieu aujourd’hui soulèvent la question de ses frontières. Où commence et où s’arrête le DIP européen ?
Download or read book European Private International Law written by Geert van Calster and published by Bloomsbury Publishing. This book was released on 2016-04-21 with total page 813 pages. Available in PDF, EPUB and Kindle. Book excerpt: As one of the most definitive texts on the market, European Private International Law provides an essential guide for both students and practitioners to the complex field of international litigation within the EU. The private international law of the Member States is increasingly regulated by European law, making private international law ever less 'national' and ever more EU based. Consequentially EU law in this area has penetrated national law to a very high degree, making it an essential area of study and an area of increasing importance to practising lawyers. This book provides a thorough overview of core European private international law, including the Brussels I, Rome I and Rome II Regulations (jurisdiction, applicable law for contracts and tort), while additional chapters deal with the recently adopted Succession Regulation, private international law and insolvency, freedom of establishment, and the impact of PIL on corporate social responsibility. From the reviews of the first edition 'As a result of his broad knowledge on the subject and rich professional experience, Mr van Calster provides great insight into current issues within international law. The book is practical as both a student textbook and a general introduction for legal professionals'. Vladimir Cupryszak, Association for International Arbitration 'Excellent overview of European Private International Law issues, as well as a very helpful introduction to basic concepts of conflicts of laws and jurisdictions'. Professor Stavros Brekoulakis, Queen Mary University of London 'This is a most useful book. I recommend it to my students as a great way to come to terms with the EU elements of Private International Law'. Dr David Kenny, Trinity College Dublin 'This book is essential reading for law students in Europe and abroad. It provides a coherent overview of all main elements of European private international law; concepts, legal instruments and practice'. Professor Kim Talus, UEF Law School, Finland 'Well-written, clear and understandable. Excellent value for money'. Dr Jan Oster, King's College London, UK
Download or read book Research Methods in Private International Law written by Xandra Kramer and published by Edward Elgar Publishing. This book was released on 2024-05-02 with total page 409 pages. Available in PDF, EPUB and Kindle. Book excerpt: This incisive Research Handbook provides valuable insights into the various methodological approaches to Private International Law from regulatory and educational perspectives. It comprehensively unpacks central themes in the field including international jurisdiction, recognition and enforcement, and scrupulously analyses core debates whilst addressing legislative and policy issues.
Download or read book A Treatise on Private International Law written by John Westlake and published by . This book was released on 1880 with total page 380 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book 2011 written by Andrea Bonomi and published by Walter de Gruyter. This book was released on 2012-07-30 with total page 716 pages. Available in PDF, EPUB and Kindle. Book excerpt: The current volume of the "Yearbook of Private International Law" includes three special sections: The first one is devoted to the recent European developments in the area of family law like the proposal on the matrimonial property régimes in its relation with other EU instruments, such as Brussels IIbis or Rome III. Another special section deals with the very hotly debated question of the treatment of and access to foreign law. The third one presents some recent reforms of national Private International Law systems. National reports and court decisions complete the book. Recent highlights include: - multiple nationalities in EU Private International Law - the European Court of Human Rights and Private International Law - parallel litigation in Europe and the US - arbitration and the powers of English courts - conflict of laws in emission trading - res judicata effects of arbitral awards
Download or read book European Private International Law written by G. Van Calster and published by . This book was released on 2020 with total page 1235 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Inquiries in International Law Public and Private written by James Reddie and published by . This book was released on 1851 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Assignment in European Private International Law written by Axel Flessner and published by . This book was released on 2006 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book European Private International Law written by G. Van Calster and published by . This book was released on 2018 with total page 1108 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Principles Definitions and Model Rules of European Private Law written by Study Group on a European Civil Code and published by sellier. european law publ.. This book was released on 2008 with total page 406 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this volume, the Study Group and the Acquis Group present the first academic Draft of a Common Frame of Reference (DCFR). The Draft is based in part on a revised version of the Principles of European Contract Law (PECL) and contains Principles, Definitions and Model Rules of European Private Law in an interim outline edition. It covers the books on contracts and other juridical acts, obligations and corresponding rights, certain specific contracts, and non-contractual obligations. One purpose of the text is to provide material for a possible "political" Common Frame of Reference (CFR) which was called for by the European Commission's Action Plan on a More Coherent European Contract Law of January 2003.
Download or read book European Private International Law written by Silvia Marino (juriste).) and published by . This book was released on 2024 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The European Private International Law of Obligations written by Richard Plender and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book When Private International Law Meets Intellectual Property Law written by World Intellectual Property Organization and published by WIPO. This book was released on 2019-10-15 with total page 92 pages. Available in PDF, EPUB and Kindle. Book excerpt: Co-published by WIPO and the Hague Conference on Private International Law, this guide is a pragmatic tool, written by judges, for judges, examining how private international law operates in intellectual property (IP) matters. Using illustrative references to selected international and regional instruments and national laws, the guide aims to help judges apply the laws of their own jurisdiction, supported by an awareness of key issues concerning jurisdiction of the courts, applicable law, the recognition and enforcement of judgments, and judicial cooperation in cross-border IP disputes.
Download or read book Essays in Private International Law written by Peter Machin North and published by Oxford University Press. This book was released on 1993 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: The nine essays collected here, some originally delivered as lectures, others written as law journal articles, have all appeared over the past fifteen years. They examine issues of topical importance in the three traditional areas of private international law: the jurisdiction of the courts, choice of the applicable law, and the recognition of foreign judgments. These areas are discussed with reference to a wide range of subject issues, in particular contract, tort, family law, and some aspects of property law. A major theme is reform and change, not only within the United Kingdom, but also as a consequence of developments within the European Community and in the light of proposals in the U.S. and worldwide.
