English Law Clause in Agreement Not Determinative of Approach to Corporate Veil in 'rule B' Attachment to Enforce a Pending Foreign Award Against Assets Traced in US
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Redman, Michael
Article from: TDM 4 (2013), in Ten years of Transnational Dispute Management (TDM)
Abstract
In an admiralty action to secure a pending
foreign arbitral award, the US Second Circuit Court of Appeals ruled that a
veil piercing claim will be subject to a conflict of laws analysis and will
take into account assets traced within the jurisdiction. A piercing claim based
on an alter ego analysis will not be defeated by automatically having to apply
the English law provisions of the underlying contract.
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Suggested Citation
M. Redman; "English Law Clause in Agreement Not Determinative of Approach to Corporate Veil in 'rule B' Attachment to Enforce a Pending Foreign Award Against Assets Traced in US"
TDM 4 (2013), www.transnational-dispute-management.com
URL: www.transnational-dispute-management.com/article.asp?key=1973
