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.
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