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What is Heinonline about?
This document discusses the inconsistent application of the center of main interests (COMI) definition in cross-border insolvency cases. It analyzes how the UNCITRAL Model Law and European regulations approach COMI and compares this to approaches in US law. The article recommends standardizing COMI factors internationally and providing more guidance to reduce forum shopping.
- Author
- jiuhi
- Language
- EN