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Chapter 15 Comity Jurisdiction

Kramer Levin Naftalis & Frankel LLP

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

Jones Day

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

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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

Jones Day

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

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"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

Jones Day

Florida Bankruptcy Court Refuses to Recognize Pre-Judgment Asset Freeze Order of Brazilian Bankruptcy Court as Being Manifestly...

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The expansion of global commerce in recent years has been accompanied by a significant increase in the volume of cross-border bankruptcy cases. Many of those cases involve "recognition" of foreign bankruptcy or insolvency...more

Jones Day

Third Circuit Updates Its Standard for Granting Comity to Foreign Bankruptcy Proceedings

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"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

Jones Day

N.Y. District Court Rules that Chapter 15 Recognition Not Required to Enforce Foreign Bankruptcy Injunction

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U.S. courts have a long-standing tradition of recognizing or enforcing the laws and court rulings of other nations as an exercise of international "comity." It has been generally understood that recognition of a foreign...more

Jones Day

Illinois Bankruptcy Court Examines Statutory Authority for Enforcing Foreign Bankruptcy Court Orders in Chapter 15 Cases

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In cases under both chapter 15 of the Bankruptcy Code and its repealed predecessor, section 304, U.S. bankruptcy courts have routinely recognized and enforced orders of foreign bankruptcy and insolvency courts as a matter of...more

Jones Day

New York District Court Rules That Chapter 15 Recognition Is Not Prerequisite to Enforcement of Foreign Bankruptcy Judgment Under...

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U.S. courts have a long-standing tradition of recognizing or enforcing the laws and court rulings of other nations as an exercise of international "comity." Since chapter 15 of the Bankruptcy Code was enacted in 2005, it has...more

Jones Day

Bankruptcy Court in Chapter 15 Case Refuses to Extend Comity to Gibbs Rule in Enforcing Croatian Settlement Modifying English-Law...

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For more than a century, courts in England and Wales have refused to recognize or enforce foreign court judgments or proceedings that discharge or compromise debts governed by English law. In accordance with a rule (the...more

A&O Shearman

Keep Comity and Carry On: US Bankruptcy Court Grants Recognition and Enforcement of a Foreign Debtors’ Settlement Agreement...

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Parties involved in cross-border bankruptcy /restructuring situations may be wary of the risk that repeated litigation in different courts with jurisdiction over the same debtor will result in conflicting judgments. The...more

Jones Day

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

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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

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