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Business Restructuring Review November–December 2023 | Vol. 22 No. 6

Health Care Provider Bankruptcy Update: Patient Care Ombudsman Not Necessary In Every Health Care Business Bankruptcy Case - Recent headlines have starkly illuminated the headwinds facing health care providers struggling...more

New York Bankruptcy Court: Foreign Representative in Chapter 15 Case Need Not Be Appointed by Foreign Court

In most cases seeking recognition of a foreign bankruptcy proceeding in the United States under chapter 15 of the Bankruptcy Code, the foreign debtor's "foreign representative" has been appointed by the foreign court or...more

Business Restructuring Review July-August 2023 | Vol. 22 No. 4

There is longstanding controversy concerning the validity of third-party release provisions in non-asbestos trust chapter 11 plans that limit the potential exposure of various nondebtor parties involved in the process of...more

California Bankruptcy Court Examines Chapter 15 Discovery Rules

In In re Golden Sphinx Ltd., 2023 WL 2823391 (Bankr. C.D. Cal. Mar. 31, 2023), the U.S. Bankruptcy Court for the Central District of California denied a motion filed by a creditor of a chapter 15 debtor seeking discovery from...more

Business Restructuring Review | May–June 2023 | Vol. 22 No. 3

Section 363(m) of the Bankruptcy Code provides that the reversal or modification of an order approving a sale or lease of assets in bankruptcy does not affect the validity of the sale or lease to a good-faith purchaser or...more

Chapter 15 Recognition Order and Relief Could Be Modified After Conversion of Foreign Debtor's Reorganization to Liquidation

Corporate restructurings are not always successful for many reasons. As a consequence, the bankruptcy and restructuring laws of the United States and many other countries recognize that a failed restructuring may be followed...more

Chapter 15 Recognition Limited to Foreign Insolvency, Liquidation, or Restructuring Proceedings

In In re Global Cord Blood Corp., 2022 WL 17478530 (Bankr. S.D.N.Y. Dec. 5, 2022), the U.S. Bankruptcy Court for the Southern District of New York denied without prejudice a petition filed by the joint provisional liquidators...more

Foreign Representative's Failure to Communicate with Bankruptcy Court Warrants Closure of Chapter 15 Case

Like debtors, bankruptcy trustees, official committees, examiners, and estate-compensated professionals, foreign representatives in chapter 15 cases have statutory reporting obligations to the bankruptcy court and other...more

Business Restructuring Review Vol. 21, No. 6 | November-December 2022

On October 14, 2022, the U.S. Court of Appeals for the Fifth Circuit issued a long-awaited ruling on whether Ultra Petroleum Corp. (“UPC”) must pay a $201 million make-whole premium to noteholders under its confirmed chapter...more

U.S. Bankruptcy Court Can Enforce Foreign Restructuring Plan Providing for Cancellation of U.S. Law-Governed Debt

Even before chapter 15 of the Bankruptcy Code was enacted in 2005 to govern cross-border bankruptcy proceedings, the enforceability of a foreign court order approving a restructuring plan that modified or discharged U.S....more

Business Restructuring Review | May–June 2022

FIFTH CIRCUIT WEIGHS IN ON BANKRUPTCY ASSET SALES FREE AND CLEAR OF LEASEHOLD INTERESTS - The ability of a trustee or chapter 11 debtor-in-possession (“DIP”) to sell bankruptcy estate assets “free and clear” of competing...more

Florida District Court: Foreign Debtor Need Not Have U.S. Residence, Assets, or Place of Business to Be Eligible for Chapter 15...

Courts disagree over whether a foreign bankruptcy case can be recognized under chapter 15 of the Bankruptcy Code if the foreign debtor does not reside or have assets or a place of business in the United States. In 2013, the...more

Business Restructuring Review | March–April 2022

MODIFICATION OF SECURED LOAN UNDER CRAMDOWN CHAPTER 11 PLAN WARRANTED DUE TO PLAN FEASIBILITY THREAT - Many recent court rulings concerning the treatment of secured creditors under a chapter 11 plan have focused on...more

Florida Bankruptcy Court Defers to Brazilian Court in Dismissing Chapter 15 Adversary Proceeding

The foundation of chapter 15 of the Bankruptcy Code and similar legislation enacted by other countries to govern cross-border bankruptcy cases is "comity" and cooperation among U.S. and foreign courts. The importance of these...more

Florida Bankruptcy Court Rules that Foreign Debtor Need Not Have U.S. Residence, Assets, or Place of Business to Be Eligible for...

Courts disagree over whether a foreign bankruptcy case can be recognized under chapter 15 of the Bankruptcy Code if the foreign debtor does not reside or have assets or a place of business in the United States....more

New York Bankruptcy Court Rules that Good Faith Is Not the Gatekeeper to Chapter 15

Despite the absence of any explicit directive in the Bankruptcy Code, it is well understood that a debtor must file a chapter 11 petition in good faith. The bankruptcy court can dismiss a bad faith filing "for cause,"...more

Business Restructuring Review | November–December 2021

New York Bankruptcy Court Rules That Good Faith Is Not The Gatekeeper To Chapter 15 - Despite the absence of any explicit directive in the Bankruptcy Code, it is well understood that a debtor must file a chapter 11...more

Eleventh Circuit Splits From Second Circuit on Finality of Chapter 15 Discovery Orders

Chapter 15 petitions seeking recognition in the United States of foreign bankruptcy proceedings have increased significantly during the more than 16 years since chapter 15 was enacted in 2005. Among the relief commonly sought...more

New York Bankruptcy Court Rules that Good Faith Is Not the Gatekeeper to Chapter 15

Despite the absence of any explicit directive in the Bankruptcy Code, it is well understood that a debtor must file a chapter 11 petition in good faith. The bankruptcy court can dismiss a bad faith filing "for cause," which...more

Business Restructuring Review | July-August 2021

Chapter 15 Update: U.S. Bankruptcy Court Refuses To Enforce Order Approving Indonesian Debt Restructuring Plan Due To Third-party Releases - Cross-border bankruptcy cases filed in the U.S. under chapter 15 of the...more

U.S. Bankruptcy Code Tolling Provision Applies in Chapter 15 Case to Extend Deadlines Under Foreign Bankruptcy Law

In In re Bankr. Est. of Norske Skogindustrier ASA, 2021 WL 1687903 (Bankr. S.D.N.Y. Apr. 29, 2021), the U.S. Bankruptcy Court for the Southern District of New York held that a foreign representative in a case under chapter 15...more

Chapter 15 Update: U.S. Bankruptcy Court Refuses to Enforce Order Approving Indonesian Debt Restructuring Plan Due to Third-Party...

Cross-border bankruptcy cases filed in the U.S. under chapter 15 of the Bankruptcy Code on behalf of foreign businesses doubled during 2020 and are on pace to set another record-breaking year in 2021 (with more than 123...more

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