The belle époque of common law universalism is not over — in fact, it is about to begin

Harneys' Ian Mann discusses international insolvency law, specifically examining a common law option as an alternative to the Singapore Model Law. Given the increasingly international nature of insolvency law, navigating the questions (coined "threading the needle") over the extent to which foreign insolvency proceedings/judgments should be recognised and/or given effect in jurisdictions outside those in which they are being mainly conducted can prove challenging.

This article, originally published on Westlaw Today, discusses international insolvency law, specifically comparing offshore and Hong Kong common law recognition with recognition under the Singapore Model Law.

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