PT  - JOURNAL ARTICLE
AU  - Steven J. Weisz
AU  - Karen S. Park
TI  - A Tale of Two Duties
AID  - 10.3905/jpe.2006.628344
DP  - 2006 Feb 28
TA  - The Journal of Private Equity
PG  - 105--114
VI  - 9
IP  - 2
4099  - https://pm-research.com/content/9/2/105.short
4100  - https://pm-research.com/content/9/2/105.full
AB  - This article explores the intersection between the need for judicial cooperation and comity in the coordination of multinational insolvency proceedings, on the one hand, and the duty of the courts to uphold state sovereignty, on the other. It explores this intersection from a uniquely Canadian perspective: a pluralistic, as opposed to a purely territorial or universal, approach, using examples of Canada-United States cross-border insolvencies. The article also briefly discusses the UNCITRAL Model Law and the potential impact, if any, of its recent adoption in principle into Canadian legislation.TOPICS: Private equity, developed, financial crises and financial market history