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Recent Chapter 15 Cases Show Potential for Non-Consensual Third-Party Releases Based Upon Foreign (Non-U.S.) Proceedings

Last year, the U.S. Supreme Court barred the use of nonconsensual third-party releases in Chapter 11 cases, holding that the Bankruptcy Code did not provide a basis to nonconsensually release claims against third parties...more

Chapter 15 Case Demonstrates Its Effectiveness as an Expedient Judicial Solution for Singaporean Insolvencies in the United States

Chapter 15 of the Bankruptcy Code (which is based upon the UNCITRAL Model Law on Cross-Border Insolvency) is designed to facilitate cross-border cooperation and coordination among courts during a pending bankruptcy or...more

Delaware Bankruptcy Judge Rejects 'Consensual' Releases in Emerge Energy Chapter 11 Plan

The Honorable Karen B. Owens, sworn in as a Delaware Bankruptcy Judge on June 17, 2019, recently ruled that the third-party releases contained in Emerge Energy Services LP’s Chapter 11 plan were not consensually granted,...more

Delaware Bankruptcy Court Finds that Section 546(e) Does Not Protect Fraudulent Transfers Following Supreme Court’s Ruling in...

In one of the first applications of the Supreme Court’s ruling on the scope of section 546(e) in Merit Management, Delaware Bankruptcy Court Judge Carey found that section 546(e)’s safe harbor did not apply to fraudulent...more

Delaware District Court Holds That a $30 Million Haircut Is Not Unfair Discrimination in a Cramdown Plan

After the Third Circuit found that the appeal of confirmation of the Tribune Plan by two senior notes trustees was not equitably moot, Judge Sleet of the Delaware District Court held that the Tribune Plan’s failure to...more

Eighth Circuit Holds that Non-Profit, Non-Bankrupt Entities are Insulated from Substantive Consolidation

The Bottom Line: The Eighth Circuit affirmed the District Court of Minnesota and the Bankruptcy Court in holding that section 303(a) of the Bankruptcy Code prohibits the substantive consolidation of non-debtor non-profit...more

Supreme Court Lakeridge Decision Clarifies the Standard of Review of Mixed Questions of Law and Fact

In another decision affecting Chapter 11 cases, U.S. Bank National Association v. Village at Lakeridge, --- S. Ct. ---, 2018 WL 1143822 (2018), on March 5, 2018, the United States Supreme Court issued a unanimous decision,...more

Third Circuit Applies More Flexible Standard for WARN Exemption

The Third Circuit, in In re AE Liquidation, Inc., Case No. 16-2203 (3d Cir. Aug 04, 2017) held that the Debtors were not liable under the WARN Act for failing to warn employees of furloughs and layoffs until those furloughs...more

IRS Can Pursue “Responsible Persons” for Unpaid Trust Fund Taxes and Automatic Stay Cannot Be Used to Enjoin Collection Against...

The Puerto Rico Bankruptcy Court followed the Third Circuit in holding that the Anti-Injunction Act, which prohibits suits to restrain the assessment or collection of any tax, is not superseded by section 105(a) of the...more

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