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Business Restructuring Review - September 2019

Chapter 11 Plan Distributions Are Not Collateral Covered by Intercreditor Agreement's Waterfall Provision - In In re Energy Future Holdings Corp., 2019 WL 2535700 (3d Cir. June 19, 2019), a panel of the U.S. Court of...more

Foreign Debtor’s COMI Shift Dooms Bid for Chapter 15 Recognition

In In re O’Reilly, 598 B.R. 784 (Bankr. W.D. Pa. 2019), the U.S. Bankruptcy Court for the Western District of Pennsylvania denied the petition of a foreign bankruptcy trustee for recognition under chapter 15 of the Bankruptcy...more

Bankruptcy Court in Chapter 15 Case Refuses to Extend Comity to Gibbs Rule in Enforcing Croatian Settlement Modifying English-Law...

For more than a century, courts in England and Wales have refused to recognize or enforce foreign court judgments or proceedings that discharge or compromise debts governed by English law. In accordance with a rule (the...more

No Comity Extended to Foreign Bankruptcy Without Chapter 15 Recognition

U.S. courts have a long-standing tradition of recognizing or enforcing the laws and court rulings of other nations as an exercise of international "comity." Prior to the enactment of chapter 15 of the Bankruptcy Code in 2005,...more

Foreign Debtors’ Forum Shopping Warranted Stay of U.S. Avoidance Litigation

Even if a U.S. court has jurisdiction over a lawsuit involving foreign litigants, the court may conclude that a foreign court is better suited to adjudicate the dispute because either: (i) it would be more convenient, fair,...more

Chapter 15 Update: U.S. Venue Selection Clause Does Not Trump Distribution Scheme in Italian Restructuring Plan

In determining whether a U.S. bankruptcy court should provide the representative of a foreign debtor with various forms of assistance in a case under chapter 15 of the Bankruptcy Code, the court must consider, consistent with...more

Courts, Cooperation, and More: Incorporating Case-Specific Provisions in Insolvency Protocols - September 2017

In cross-border restructuring cases, interested parties increasingly rely on court-approved insolvency protocols to aid in managing complex insolvencies involving debtors' assets, liabilities, or operations that span...more

Second Circuit Affirms Bankruptcy Court’s Nullification of Chapter 15 Debtor’s Sale of Claim Due to Woefully Inadequate Price

In the March/April 2013 edition of the Business Restructuring Review, we reported on an opinion by the U.S. Bankruptcy Court for the Southern District of New York concluding that a chapter 15 debtor’s sale of claims against...more

Courts, Cooperation, and More: A Review of Cross-Border Insolvency Protocols

In cross-border restructuring cases, including cases under chapter 15 of the U.S. Bankruptcy Code and versions of the UNCITRAL Model Law on Cross-Border Insolvency enacted in 42 other nations or territories, interested...more

From the Top: U.S. Supreme Court to Hear Case on Scope of Section 546(e)'s Safe Harbor

On May 1, 2017, the U.S. Supreme Court agreed to hear Merit Management Group v. FTI Consulting, No. 16-784, on appeal from the U.S. Court of Appeals from the Seventh Circuit. See FTI Consulting, Inc. v. Merit Management...more

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