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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

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

The Dutch Scheme: A Valuable Addition to Cross-Border Restructuring Toolbox

The Netherlands is planning to adopt new restructuring legislation, allowing for court confirmation of extrajudicial restructuring plans (Wet Homologatie Onderhands Akkoord, or WHOA). The bill combines features of the U.S....more

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