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Cramdown of Equity in Chapter 11 Plan Requires Assessment of Equity's Value to Satisfy "Fair and Equitable" Standard

Chapter 11 plans that propose to extinguish existing equity interests because the estate does not have any value remaining after the payment of creditor claims are common. The Bankruptcy Code's "absolute priority rule"...more

Business Restructuring Review Vol. 23 No. 6 - November–December 2024

Hertz: Third Circuit Weighs In On Make-Whole Premiums And The “Solvent-debtor Exception” In Chapter 11 Cases - A handful of recent high-profile court rulings have considered whether a chapter 11 debtor is obligated to pay...more

Hertz: Third Circuit Weighs in on Make-Whole Premiums and the "Solvent-Debtor Exception" in Chapter 11 Cases

A handful of recent high-profile court rulings have considered whether a chapter 11 debtor is obligated to pay postpetition, pre-effective date interest ("pendency interest") to unsecured creditors to render their claims...more

Business Restructuring Review | March–April 2022

MODIFICATION OF SECURED LOAN UNDER CRAMDOWN CHAPTER 11 PLAN WARRANTED DUE TO PLAN FEASIBILITY THREAT - Many recent court rulings concerning the treatment of secured creditors under a chapter 11 plan have focused on...more

Cram-Down Chapter 11 Plan Need Not Strictly Enforce Subordination Agreement

In the latest chapter of more than a decade of contentious litigation surrounding the 2007 leveraged buyout ("LBO") and ensuing bankruptcy of media conglomerate Tribune Co. ("Tribune"), the U.S. Court of Appeals for the Third...more

Supreme Court Adopts Deferential Standard of Review on Chapter 11 Insider Status

In U.S. Capital Bank N.A. v. Village at Lakeridge, LLC, No. 15-1509 (U.S. Mar. 5, 2018), the U.S. Supreme Court held that an appellate court should apply a deferential standard of review to a bankruptcy court's decision as to...more

Second Circuit Rules on Chapter 11 Cram-Down, Make-Whole, and Subordination Issues

The Situation: In In re MPM Silicones, L.L.C., secured noteholders argued that replacement notes distributed to them under a cram-down chapter 11 plan should bear market-rate interest rather than the lower formula rate...more

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