One impetus for the changes to the 1984 Uniform Fraudulent Transfer Act (UFTA), now the 2014 Voidable Transactions Act (UVTA), the first in 30 years, was the need to address conflict of laws
in fraudulent transfer litigation.
For the entire contract execution is governed by German law, excluding the conflict of laws
and the exclusion of the United Nations Convention on Contracts for the International Sale of Goods of 11.
Law 6 defines articles related to conflict of laws
in civil and commercial disputes involving foreign elements.
As a way of starting to investigate that question, this Article suggests what the use of one mode of conflicts analysis--the governmental-interest approach--might look like when used in the intrastate conflict of laws
, and considers Italian Colors as an example of how it might work.
Few conflict of laws
scholars have addressed a state court's obligations when interpreting sister state law.
The Conflict of Laws
Problem and Currently Proposed Solutions A.
A prolific scholar, Maier's work in the field of international law, international civil litigation and conflict of laws
gained a global audience.
He highlighted the need to fast-track settlement of investment disputes through arbitration and avert any conflict of laws
in tackling contentious civil and trade issues.
Topics include the status of the MLC in the European Union legal order, the interplay between the new rules of the MLC and existing Maltese shipping legislation, the MLC's impact on the duties and responsibilities of the shipmaster, the impact of the MLC on yacht employment, employers liabilities for crewing insurance, new insurance products for meeting the demands of the MLC to obtain financial security to cover ship owners' liabilities, the failure of the MLC to adequately address piracy, and the European conflict of laws
system that governs seafaring employment disputes.
COMPARATIVE ANALYSIS OF PROPRIETARY RESTITUTION IN THE DOMESTIC LAW AND THE CONFLICT OF LAWS
One of the oldest theories of conflicts still in common currency is set forth in the First Restatement of Conflict of Laws
, reported in 1934 by Joseph Henry Beale.
12) Since the adoption of these rules, not a single jurisdiction has followed suit; the majority have instead elected to adopt alternative conflicts approaches, primarily that of the Second Restatement of Conflict of Laws