Global Labor and Employment Law for the Practicing Lawyer

The global labor markets require workable and predictable law, forums and jurisdiction, and recognition of judgments for the enforcement of cross-border employment contracts. When a U.S. manager posts to the United Kingdom pursuant to a contract signed in New York, will British or New York law apply to disputes arising from that employment contract? Is the result different if the U.S. citizen performs her work in France or Germany? May the parties choose the applicable law in the contract? May the parties contractually choose the forum or jurisdiction for resolving the dispute and will that affect the applicable choice of law? Will a judgment in one European Union (EU) country be honored in other EU countries and the United States, and, in the event the employer sues in the United States, will courts in the EU honor a U.S. judgment?