Penn State International Law Review

First Paragraph

The collision between an increasing number of multinational arbitrations and an increasing number of multinational insolvencies constitutes the irresistible force meeting the immoveable object. In many countries, an insolvency proceeding overrides most other laws and sweeps into its embrace virtually all legal matters relating to the debtor. Yet international arbitration as embodied in the United Nations Convention has achieved a highly favored state of enforcement around the world.