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U.S. Bankruptcy Court Directs Turnover of Chapter 15 Debtor's Assets for Administration in Foreign Bankruptcy Proceeding

Nearing its 20th anniversary, chapter 15 of the Bankruptcy Code is an invaluable framework for coordinating cross-border bankruptcy cases involving foreign debtors that have assets located in the United States. It includes a...more

Cayman Islands Branch of FDIC-Insured U.S. Bank Ineligible for Chapter 15 Relief

The Bankruptcy Code bars certain individuals or entities from filing for bankruptcy protection, generally because they do not reside or have a place of business or property in the United States, fail to satisfy certain debt...more

Double-Dip Financings: The Next Wave in European Liability Management?

A “double-dip” structure is considered a way to allow some creditors to have multiple claims against key obligors arising out of the same underlying transactions. These additional claims could improve their position relative...more

Chapter 15 Recognition Order and Relief Could Be Modified After Conversion of Foreign Debtor's Reorganization to Liquidation

Corporate restructurings are not always successful for many reasons. As a consequence, the bankruptcy and restructuring laws of the United States and many other countries recognize that a failed restructuring may be followed...more

New York Bankruptcy Court Rules that Good Faith Is Not the Gatekeeper to Chapter 15

Despite the absence of any explicit directive in the Bankruptcy Code, it is well understood that a debtor must file a chapter 11 petition in good faith. The bankruptcy court can dismiss a bad faith filing "for cause,"...more

New York Bankruptcy Court Rules that Good Faith Is Not the Gatekeeper to Chapter 15

Despite the absence of any explicit directive in the Bankruptcy Code, it is well understood that a debtor must file a chapter 11 petition in good faith. The bankruptcy court can dismiss a bad faith filing "for cause," which...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

Second Circuit: Madoff Ponzi Scheme Customers Did Not Receive Fictitious Profit Payments "For Value"

In the latest chapter of more than a decade of litigation involving efforts to recover fictitious profits paid to certain customers of Bernard Madoff's defunct brokerage firm as part of the largest Ponzi scheme in history,...more

Foreign Debtor’s COMI Shift Dooms Bid for Chapter 15 Recognition

In In re O’Reilly, 598 B.R. 784 (Bankr. W.D. Pa. 2019), the U.S. Bankruptcy Court for the Western District of Pennsylvania denied the petition of a foreign bankruptcy trustee for recognition under chapter 15 of the Bankruptcy...more

Cross-Border Bankruptcy Update: COMI Migration and Illegitimate COMI Manipulation Distinguished

With the significant increase in cross-border bankruptcy and insolvency filings in the 43 nations or territories that have adopted the UNCITRAL Model Law on Cross-Border Insolvency (the "Model Law"), including the U.S., the...more

Second Circuit Affirms Bankruptcy Court’s Nullification of Chapter 15 Debtor’s Sale of Claim Due to Woefully Inadequate Price

In the March/April 2013 edition of the Business Restructuring Review, we reported on an opinion by the U.S. Bankruptcy Court for the Southern District of New York concluding that a chapter 15 debtor’s sale of claims against...more

U.S. Supreme Court Holds That Structured Dismissals Cannot Deviate From the Bankruptcy Code's Priority Scheme

In bankruptcy cases under chapter 11, debtors sometimes opt for a "structured dismissal" when a consensual plan of reorganization or liquidation cannot be reached or conversion to chapter 7 would be too costly. In Czyzewski...more

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