The Second Circuit is currently considering an appeal arising from the decisions of the bankruptcy and district courts in Fairfield Sentry. Its opinion is likely to resolve a split of authority between the Fairfield Sentry and Millennium courts within the Southern District of New York, and could create a split with the Fifth Circuit’s decision in the Ran case. Whatever the outcome, the Second Circuit’s Fairfield Sentry decision will highlight a peculiar problem with the language of Chapter 15 of the United States Bankruptcy Code (the ‘‘Bankruptcy Code’’) that, if interpreted literally (as it usually is), often leads to results that were almost certainly unintended by Congress, including potential forum shopping by corporate debtors seeking to liquidate in countries that have favorable laws but bear little connection to their prepetition operations. Most courts that have recognized the problem have determined that they are unable to rectify it given the plain language of Chapter 15 . While the Millennium court interpreted the statute in a way that seems to be in line with the intent of both Congress and the United Nations Commission on International Trade Law (‘‘UNCITRAL’’), which drafted the model law that Chapter 15 is based upon (the ‘‘U.N. Model Law’’), that court’s interpretation of Chapter 15 is difficult to square with the plain language of the statute. To fully resolve the problem, Congress should amend Chapter 15 to make its intent clear. Fortuitously, UNCITRAL is already considering such an amendment to the U.N. Model Law.