@book{2026:abbasov:recognitio,
title = {Recognition of Restructuring Plans under the UNCITRAL Model Law on Cross-Border Insolvency},
year = {2026},
note = {This doctoral thesis analyses the recognition of restructuring plans
under the MLCBI, focusing on two jurisdictions: England and the US. It
contrasts the Gibbs rule with the approach followed under Chapter 15
and seeks to develop a balanced framework that reconciles the
interests of the debtor and dissenting foreign creditors. Unlike the
Gibbs rule, this framework does not make the recognition of a debt
discharge in foreign restructuring proceedings conditional upon the
debtor’s restructuring being conducted under the law governing that
debt. Instead, it focuses on the assessment of substantive fairness at
the recognition stage as part of the “adequate protection”
safeguard under the MLCBI to ensure the fair treatment of foreign
creditors. This Title is also Available as Open Access.},
edition = {1},
publisher = {Nomos},
address = {Baden-Baden},
series = {Schriften zur Restrukturierung},
volume = {38},
author = {Abbasov, Abbas}
}