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  • Recognizing Foreign Insolvency Judgments: Why Canada Sticks to Its Guns While the UK Bets on the Model Insolvency Law

Recognizing Foreign Insolvency Judgments: Why Canada Sticks to Its Guns While the UK Bets on the Model Insolvency Law

Aubrey Kauffman of Fasken Martineau DuMoulin and Divi Dev of Divi Distressed Investments compare and contrast the UK and Canadian approaches to the adoption of model insolvency laws, explaining why the UK needs the UNCITRAL Model Law on Recognition and Enforcement of Insolvency-Related Judgments while Canada doesn’t.