News & Analysis as of

Comity Bankruptcy Code

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

Pillsbury Winthrop Shaw Pittman LLP

U.S. Bankruptcy Court Confirms Nonconsensual Third-Party Releases May Be Recognized Under Chapter 15 of the Bankruptcy Code

A recent Bankruptcy Court decision granted recognition to a Mexican concurso mercantile and gave full force and effect to a Mexican concurso plan that contained nonconsensual third-party releases....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

Pillsbury Winthrop Shaw Pittman LLP

No Comity Tonight

U.S. Bankruptcy Court does not enforce an asset freeze order from a Brazilian insolvency proceeding recognized under chapter 15 of the Bankruptcy Code. Recognition of a foreign proceeding under chapter 15 of the Bankruptcy...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

Nelson Mullins Riley & Scarborough LLP

Cross-Border Bankruptcy Cases: Chapter 15 of the Bankruptcy Code and Parameters of a Discovery Tool

Procedure - Chapter 15 of the United States Bankruptcy Code was enacted in 2005 and represents the United States’ adoption of the “Model Law on Cross-Border Insolvency so as to provide effective mechanisms for dealing...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

Kramer Levin Naftalis & Frankel LLP

Second Circuit Confirms Madoff Trustee’s Ability to Recover Foreign Transfers

The Bottom Line - In vacating judgments from both the District Court and the Bankruptcy Court of the Southern District of New York, the Second Circuit held, in In re Picard, 917 F.3d 85 (2d Cir. 2019), that the trustee...more

A&O Shearman

The Reach of Avoidance – Second Circuit Court of Appeals Holds in Madoff that Bankruptcy Code Can Be Used to Recover Subsequent...

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On February 25, 2019, the United States Court of Appeals for the Second Circuit issued a decision holding that a trustee is not barred by either the presumption against extraterritoriality or by international comity...more

Skadden, Arps, Slate, Meagher & Flom LLP

Second Circuit Allows Avoidance Actions Against Foreign Transferees in Madoff Proceeding

On February 25, 2019, the U.S. Court of Appeals for the Second Circuit vacated the bankruptcy court’s dismissal of avoidance actions brought by Irving Picard, the trustee (Trustee) for the liquidation of Bernard L. Madoff...more

Latham & Watkins LLP

Second Circuit Backs Foreign Clawback Claims in Madoff Bankruptcy Action

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The Second Circuit holds that the presumption against extraterritoriality and international comity do not bar recovery of purely foreign transfers. Key Points: ..The Second Circuit focused on the initial transfer from...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

WilmerHale

Seeing Double? Two Judges, Two Lawsuits, Two Types of Bankruptcy - But a Single Vision for Comity in Cross-Border Insolvencies

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The recent decision in In re National Bank of Anguilla (Private Banking Trust) Ltd.1 may cause readers to do a double-take. First, it is co-authored by two bankruptcy judges: Hon. Stuart M. Bernstein and Hon. Martin Glenn....more

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