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Clarity in Singapore: How COMI Is Determined Under the UNCITRAL Model Law on Cross-Border Insolvency

In re Fullerton Capital Ltd [2025] SGCA 11, a BVI-incorporated company entered into insolvency proceedings in the British Virgin Islands ("BVI"). The liquidators sought recognition of the BVI liquidation as a "foreign main...more

Business Restructuring Review Vol. 24, No. 3 | May–June 2025

Bankruptcy trustees and chapter 11 debtors-in-possession (“DIPs”) frequently seek to avoid fraudulent transfers and obligations under section 544(b) of the Bankruptcy Code and state fraudulent transfer or other applicable...more

New York Bankruptcy Court Recognizes English Scheme of Arrangement Proceeding Under Chapter 15 Despite Concerns of Improper COMI...

Approaching its 20-year anniversary, chapter 15 of the Bankruptcy Code has proven to be an invaluable tool for facilitating cross-border bankruptcy and insolvency cases. As foreign debtors have increasingly relied on chapter...more

Take Your Seats: Cineworld Draws an Audience in UK High Court

Four UK companies within the Cineworld Group ("Cineworld") have obtained court sanction to an English-law Part 26A restructuring plan ("RP"). Cineworld became financially distressed following a prolonged period of poor...more

BHS Liquidators Win Record Wrongful Trading Judgment—and Establish New "Misfeasance Trading" Law

FRP Advisory Trading Limited won the United Kingdom's largest-ever wrongful trading claim and successfully established the first "misfeasance trading" claim against former directors of British Home Stores ("BHS"),...more

Business Restructuring Review Vol. 23 No. 2 | March–April 2024

Established in 2015 as a trusted neutral forum to meet increasing demand for effective transnational dispute resolution, the Singapore International Commercial Court (the “SICC”) is a division of the General Division of the...more

Adler: English Court of Appeal Overturns Restructuring Plan (UPDATE)

On January 23, 2024, the Court of Appeal in England and Wales (the "Appeal Court") upheld a challenge launched by dissenting creditors to overturn the UK Restructuring Plan (the "RP") of the Adler Group previously approved by...more

Adler: English Court of Appeal Overturns Restructuring Plan

The Situation: The Adler Group sought to restructure more than €6 billion of debt by means of a UK restructuring plan ("RP"), to give itself a runway for a planned wind-down and asset sales, leading to an enhanced return for...more

Milestone in Cross-Border Insolvency: A Successful Application Under the Pilot Measure from Hong Kong to Mainland China

Background of the Pilot Measure The mechanism set out in "The Supreme People's Court's Opinion on Taking Forward a Pilot Measure in relation to the Recognition of and Assistance to Insolvency Proceedings in the Hong Kong...more

Business Restructuring Review | March–April 2021

In This Issue: Tenant's Election to Retain Possession of Rejected Lease Premises Preserves Obligations Under Related Agreements - Section 365(h) of the Bankruptcy Code provides special protection for tenants if a...more

Business Restructuring Review | January–February 2021

One year ago, we wrote that the large business bankruptcy landscape in 2019 was generally shaped by economic, market, and leverage factors, with notable exceptions for disastrous wildfires, liabilities arising from the opioid...more

Directors' Duties—A European Overview: Financial Distress and COVID-19 - November 2020

A company or group's financial distress causes significant turmoil for its owners, directors, managers, employees and often its suppliers and other creditors. For directors in particular, there are significant...more

All Change In Europe—New Chapter 11-Style Restructuring Regime Is On Its Way!

On 26 June 2019, the new Harmonisation Directive was formally published in the Official Journal of the European Union. As a result, by 17 July 2021, each Member State must include in its respective insolvency and...more

UK's Proposed Corporate Restructuring Regime Follows European-Style Chapter 11 and Debtor-in-Possession Trend

The UK Government has announced proposals to introduce a new UK restructuring plan and moratorium, together with certain other changes to the corporate governance regime relevant to companies in distress. In addition,...more

Singapore Enacts New Corporate Bankruptcy Law in Bid to Become Center for International Debt Restructuring

On March 10, 2017, Singapore's Parliament approved the Companies (Amendment) Bill 2017 (the "Act") to enhance the country's corporate debt restructuring framework. The Act, a copy of which is available here, was assented to...more

Singapore, Delaware, and New York Courts Adopt Cross-Border Insolvency Cooperation Guidelines

The Action: Courts in Singapore and the states of New York and Delaware have formally implemented Guidelines for Communication and Cooperation between Courts in Cross-border Insolvency Matters....more

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