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Search Results for : Applicable Conflict-of-Laws System
Author: Michael Sweig* Jurisdictions: British Columbia Canada Baja California Sur Mexico Topics: Applicable Conflict-of-Laws System Enforcement of Arbitral Awards Relief and Remedies in General I. Introduction A shareholder loan creditor...
Dépeçage in International Commercial Arbitration
...problem courts may face is that conflict-of-law rules applicable to contracts only regulate contractual obligations, so courts will need to interpret that the conflict-of-law rule applicable to the contract could...
What Should Be the Applicable Law to Arbitration Agreements?
...out with a general description of a conflict, followed by example(s) of the conflict that could arise. The paper will then illustrate how the conflict is dealt with by the...
The Advisory Centre on International Investment Law (ACIIL) and the ...
...(2) For this purpose the choice of the laws of a country shall be understood to refer to the substantive laws of that country and not its conflict of laws...
The Recent Amendment of Italy’s Arbitration Law and the Ongoing ...
...ICSID arbitrations silent on the applicable rules? Where the applicable rules are not determined by an arbitration agreement, parties’ autonomy can configure the applicable rules. Failing an agreement of the...
A Potentially Vast Procedural Framework for ICSID Arbitration Provisions Silent ...
...explained below. It makes international sales more consistent, reducing the confusion caused by different local laws. Using it in government contracts can be complicated due to conflicts with national laws,...
Government Contracts and the CISG: Frenemies?
Author: Yilin Tim Chen* Published: May 2018 Jurisdictions: United States International Topics: Agreement to Arbitrate Proceedings to Compel Arbitration Applicable Conflict-of-Laws System Commercial Disputes New York Convention FAA Defects and...
A Harmonizing Framework for Choice-of-Law Practices in U.S. Judicial Enforcement ...
...“Conflicts of Interest in International Arbitration: Debates and dilemmas surrounding third-party funding and party representation.”[1] The regulation of conflicts of interest is not dissimilar to walking on a tightrope. From...
TagTime with Cecilia Azar – Conflicts of Interest in International ...
...the IBA Guidelines on Conflicts of Interest in International Arbitration, wherein an arbitrator’s conflict with a counsel and an arbitrator’s conflict with an expert are contained under the same heading...
Crystalizing Jurisprudence: Assessing An Arbitral Tribunal’s Competence To Exclude A ...
...counsel is not since they come from different jurisdictions. OVERVIEW OF APPLICABLE RULES The issue with legal privilege and commercial confidence would be less problematic if there were universal applicable...
TagTime with Samaa Haridi – Legal Privilege in International Commercial ...
...how similar principles might assist fragile negotiations or post-conflict implementation in several contemporary contexts. The argument is not that arbitration can resolve conflicts in their entirety. Nor is it to...