Approaching its 20-year anniversary, chapter 15 of the Bankruptcy Code has proven to be an invaluable tool for facilitating cross-border bankruptcy and insolvency cases. As foreign debtors have increasingly relied on chapter...more
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
Judicial comments cast doubt on the ability to compromise US law-governed debt effectively based on Chapter 15 recognition alone. A recent first instance decision in Hong Kong has highlighted an important...more
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