The composition of the debtor's estate on insolvency: A comparative study of exemptions |
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| Authors: | Donna McKenzie Skene |
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| Affiliation: | School of Law, University of Aberdeen, Aberdeen, UKSenior Lecturer, The author gratefully acknowledges the award of a travel grant by the British Academy to assist with her travel expenses for presenting the original paper at the INSOL Academics Group Meeting in Vancouver in June 2009, although she was ultimately unable to attend the meeting and present the paper personally due to a family bereavement. The author also gratefully acknowledges the helpful comments on an earlier draft of this paper by Professor Adrian Walters, Nottingham Law School, in respect of which the usual disclaimer applies. |
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| Abstract: | This article examines one aspect of the issue of the composition of the debtor's estate on insolvency, namely the exemption of certain assets from the debtor's estate. It sets out the responses to a questionnaire completed by leading scholars in selected jurisdictions (Australia, Canada, France, Italy, New Zealand, South Africa, The Netherlands and the USA) on the exemptions available in those jurisdictions, makes preliminary observations on those responses, considers the prospects for harmonisation of this area of law in the light of those observations and puts forward some tentative proposals for the development of model provisions and/or legislative principles in the area of exemptions for comment and discussion. Copyright © 2011 John Wiley & Sons, Ltd. |
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