News & Analysis as of

Foreign Jurisdictions Commercial Bankruptcy Insolvency

Jones Day

New Jersey Bankruptcy Court Ruling Highlights the Utility of Chapter 15 in Enforcing Foreign Bankruptcy Court Orders in the United...

Jones Day on

"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

Walkers

Jersey Company Law Series: Migration / Continuation – Moving companies to and from Jersey

Walkers on

Effects of a company migration into - Jersey Steps to migrate a company out of Jersey...more

Mayer Brown

To Be Or Not To Be (Solvent) - A Comparative Analysis Of Singapore, UK, US, And Australia On Recognising Foreign Proceedings...

Mayer Brown on

The recent case of Ascentra Holdings, Inc v. SPGK Pte Ltd [2023] SGCA 32 (Ascentra) has drawn a line in the sand in the Singapore court's interpretation of the UNCITRAL Model Law on Cross-Border Insolvency (UNCITRAL Model...more

Goodwin

A Brief Defense of COMI

Goodwin on

For a foreign proceeding to be recognized under the UNCITRAL Model Law on Cross-Border Insolvency (“Model Law”) and its offspring, chapter 15 of the Bankruptcy Code, the foreign proceeding must be either a foreign main...more

Hogan Lovells

Hong Kong and mainland China agree new co-operation mechanism for cross-border insolvency

Hogan Lovells on

Hong Kong and the Mainland have agreed a new co-operation mechanism for cross-border insolvency. Under the agreement, liquidators from Hong Kong may apply to Mainland courts for recognition of insolvency proceedings in Hong...more

Hogan Lovells

A welcome red packet – Hong Kong court recognises mainland Chinese administrators for first time

Hogan Lovells on

Just in time for Chinese New Year, a Hong Kong court has taken a major step forward in the developing law on cross-border insolvency by recognising a mainland Chinese liquidation for the first time. ...more

Jones Day

Delaware Bankruptcy Court Adopts Interim Modalities for Court Communication in Cross-Border Bankruptcies

Jones Day on

After discussions among judges from several jurisdictions, including Argentina, Australia, Bermuda, the British Virgin Islands, Canada, the Cayman Islands, England and Wales, Singapore, and the United States, at the initial...more

Jones Day

English Court of Appeal Upholds "The Gibbs Rule"

Jones Day on

The Situation: In Bakhshiyeva v Sberbank of Russia, a debtor sought to restructure English law-governed debts pursuant to an Azerbaijani restructuring proceeding. In order to prevent certain dissenting creditors from...more

Jones Day

New UNCITRAL Model Law on the Recognition and Enforcement of Insolvency-Related Judgments

Jones Day on

On September 18, 2018, the United Nations Commission on International Trade Law ("UNCITRAL") published its final version of the new Model Law on the Recognition and Enforcement of Insolvency-Related Judgments (the "IRJ Model...more

Jones Day

Singapore, Delaware, and New York Courts Adopt Cross-Border Insolvency Cooperation Guidelines

Jones Day on

The Action: Courts in Singapore and the states of New York and Delaware have formally implemented Guidelines for Communication and Cooperation between Courts in Cross-border Insolvency Matters....more

10 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide