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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

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

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

First Impressions: Singapore International Commercial Court Approves Cross-Border Prepackaged Scheme of Arrangement for...

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

Singapore Court Issues Landmark Decision Recognizing Indonesian Restructuring Plan

The Singapore International Commercial Court ("SICC") has handed down its first insolvency-related ruling. The court granted recognition and full force and effect to Indonesia's flagship airline's restructuring plan. That...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

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