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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 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

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

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