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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. 4 | July–August 2025

The Ad Hoc Group of Senior Secured Noteholders and DIP Lenders (the “Ad Hoc Group”) obtained a unanimous judgment in their favor in an appeal following Sanchez Energy Company’s long-running, hard-fought bankruptcy case. Once...more

New York Bankruptcy Court Examines COMI for Purposes of Chapter 15 Recognition of Foreign Restructuring Proceedings Involving...

As chapter 15 of the Bankruptcy Code quickly approaches its 20th anniversary in a global economy, the volume of cross-border bankruptcy cases has rapidly escalated. With multinational companies having affiliates throughout...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

Revisiting Singapore's Corporate Restructuring and Insolvency Regime: Cross-Class Cramdown in Schemes of Arrangement

On March 11, 2025, the Committee to Enhance Singapore's Corporate Restructuring and Insolvency Regime (the "Committee") published a report (the "Report") outlining its recommendations to further enhance and modernize...more

U.S. Bankruptcy Court Directs Turnover of Chapter 15 Debtor's Assets for Administration in Foreign Bankruptcy Proceeding

Nearing its 20th anniversary, chapter 15 of the Bankruptcy Code is an invaluable framework for coordinating cross-border bankruptcy cases involving foreign debtors that have assets located in the United States. It includes a...more

Business Restructuring Review Vol. 24 No. 1 | January–February 2025

The Year in Bankruptcy: 2024 - A brief chronicle of the year's notable developments in corporate bankruptcy and restructuring, including business bankruptcy filings, significant court rulings, and legislative...more

The Year in Bankruptcy: 2024

The first full year of the post-COVID-pandemic era was characterized in the United States by continued economic recovery, persistently high consumer interest rates—despite three cuts in the benchmark federal funds rate in...more

Filing of Adversary Proceeding Against Chapter 15 Debtor Violated Automatic Stay, and "Home Court" Rule Does Not Apply in Chapter...

It is generally well understood that an order of a U.S. bankruptcy court recognizing a debtor's foreign bankruptcy case as a "main" proceeding under chapter 15 of the Bankruptcy Code triggers the automatic stay preventing...more

Ninth Circuit: Reversal on Appeal of Order Denying Chapter 15 Recognition Does Not Retroactively Trigger Automatic Stay

It is generally recognized that an order of a U.S. bankruptcy court recognizing a debtor's foreign bankruptcy proceeding as a "main" proceeding under chapter 15 of the Bankruptcy Code triggers the automatic stay preventing...more

Business Restructuring Review Vol. 23 No. 6 - November–December 2024

Hertz: Third Circuit Weighs In On Make-Whole Premiums And The “Solvent-debtor Exception” In Chapter 11 Cases - A handful of recent high-profile court rulings have considered whether a chapter 11 debtor is obligated to pay...more

Business Restructuring Review Vo. 23 No. 5 - September–October 2024

The Singapore International Commercial Court (the "SICC"), a division of the General Division of the High Court and part of the Supreme Court of Singapore, was established in 2015 as a trusted neutral forum to meet increasing...more

Ownership Dispute Regarding Foreign Debtor's U.S. Assets Must Be Resolved Before a U.S. Bankruptcy Court Can Approve Sale Under...

As the enactment of chapter 15 of the Bankruptcy Code approaches its 20-year anniversary, U.S. bankruptcy courts are still grappling with some unresolved issues concerning how its provisions should be applied to best...more

Business Restructuring Review Vol. 23 No. 4 | July–August 2024

The U.S. Supreme Court handed down three bankruptcy rulings to finish the current Term. The decisions address the validity of nonconsensual third-party releases in chapter 11 plans, the standing of insurance companies to...more

Circuit Split: Eleventh Circuit and Second Circuit Disagree on Eligibility Requirements for Chapter 15 Debtors

Courts disagree over whether a foreign bankruptcy case can be recognized under chapter 15 of the Bankruptcy Code if the foreign debtor does not reside or have assets or a place of business in the United States. In 2013, the...more

U.S. Supreme Court Bankruptcy Update

The U.S. Supreme Court handed down three bankruptcy rulings to finish the Term ended in July 2024. The decisions address the validity of nonconsensual third-party releases in chapter 11 plans, the standing of insurance...more

Business Restructuring Review Vol. 23 No. 3 | May-June 2024

In In re Pack Liquidating, LLC, 2024 WL 409830 (Bankr. D. Del. Feb. 2, 2024), the U.S. Bankruptcy Court for the District of Delaware ruled that, in accordance with Third Circuit precedent, the Bankruptcy Code, rather than...more

Cayman Islands Branch of FDIC-Insured U.S. Bank Ineligible for Chapter 15 Relief

The Bankruptcy Code bars certain individuals or entities from filing for bankruptcy protection, generally because they do not reside or have a place of business or property in the United States, fail to satisfy certain debt...more

Third Circuit Updates Its Standard for Granting Comity to Foreign Bankruptcy Proceedings

"Comity" is a principle of jurisprudence whereby, under appropriate circumstances, one country recognizes within its borders the legislative, executive, or judicial acts of another nation. Many recent court rulings have...more

Delaware Bankruptcy Court: "Center of Main Interests" for Purposes of Chapter 15 Recognition Must Be Determined on...

Determining a foreign debtor's "center of main interests" ("COMI") for purposes of recognizing a foreign bankruptcy proceeding in the United States under chapter 15 of the Bankruptcy Code can be problematic in cases...more

The Adler Aftermath: From Colombia to Germany, Junior Creditors Crammed and Compromised

Following the seminal Adler judgment, the English Court has now ruled on a further two contested restructuring plans ("RPs"). These two judgments provide important commentary relevant to all parties considering or affected by...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

Singapore International Commercial Court Issues First Decision on Recognition of Cross-Border Bankruptcy Cases under Model Law

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

The Year In Bankruptcy: 2023

One year ago, we wrote that 2022 would be remembered in the corporate bankruptcy world for the "crypto winter" that descended in November 2022 with the spectacular collapse of FTX Trading Ltd., Alameda Research, and...more

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