The UNCITRAL Model Law on Cross-Border Insolvency Comes of Age: New Times or New Paradigms?
Bibliographic record
Abstract
In 2018, the Model Law on Cross-Border Insolvency celebrated its 21st birthday. The Model Law has been something of a success internationally. Based on the Model Law provisions, many major common law jurisdictions, including the United Kingdom (UK), the United States (US), Canada, and Australia, have changed their domestic laws on cross-border insolvency cooperation, and so too have Japan and Korea. However, the emerging global super powers of China and India, and most of the European Union (EU) member states including the economic power houses of France and Germany-have remained resistant. Nevertheless, the number of international acceptances is growing slowly, most recently including Singapore. The Government of India recently issued a draft chapter to be included in the Insolvency and Bankruptcy Code 2016 and is also in the process of considering whether to subscribe to the Model Law. This paper critically assesses the basic paradigm of cross-border insolvency cooperation as reflected in the Model Law, the Model Law as a potential vehicle for harmonization, and the Model Law's limits while facilitating such cross-border cooperation.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.009 | 0.019 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.006 | 0.035 |
| Scholarly communication | 0.019 | 0.023 |
| Open science | 0.002 | 0.006 |
| Research integrity | 0.008 | 0.017 |
| Insufficient payload (model declined to judge) | 0.006 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".