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Bankruptcy Code Cross-Border Jurisdiction

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

Patterson Belknap Webb & Tyler LLP

Courts Split Over Requirement for Chapter 15 Jurisdiction in the U.S.

To file bankruptcy in the U.S., a debtor must reside in, have a domicile or a place of business in, or have property in the United States. 11 U.S.C. § 109(a). In cross border chapter 15 cases, courts have considered whether...more

Jenner & Block

Compilation of Recent Developments in Bankruptcy Law - April 2023

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Recent Developments in Bankruptcy Law - Cumulative, through April 2023 - 1. AUTOMATIC STAY - 1.1 Covered Activities - 1.1.a Court denies injunction against actions involving debtors’ affiliates. Shortly after filing...more

Jenner & Block

Compilation of Recent Developments in Bankruptcy Law - January 2023

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1. AUTOMATIC STAY - 1.1 Covered Activities - 1.1.a Court declines to enjoin third party claims against the debtor’s jointly liable parent corporation. The debtor manufactured earplugs for many years. A major...more

Latham & Watkins LLP

Cross-Border Recognition: Hong Kong Schemes and the Compromise of Foreign Law-Governed Debt

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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

Patterson Belknap Webb & Tyler LLP

A Bankruptcy Code Chapter 15 Primer: Decision in New York Addresses Key Issues of Jurisdiction, Recognition, Public Policy, and...

Judge Martin Glenn last week issued a decision in two related chapter 15 cases, In re Foreign Econ. Indus. Bank Ltd. “Vneshprombank” Ltd., No. 16-13534, and In re Larisa Markus, No. 19-10096, 2019 Bankr. LEXIS 3203 (Bankr....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

Jones Day

Foreign Debtors’ Forum Shopping Warranted Stay of U.S. Avoidance Litigation

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Even if a U.S. court has jurisdiction over a lawsuit involving foreign litigants, the court may conclude that a foreign court is better suited to adjudicate the dispute because either: (i) it would be more convenient, fair,...more

Hogan Lovells

Countering counterparty insolvency

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These days, the threat of counterparty insolvency looms over the energy sector: whether it is a natural disaster or precipitous decline in the price of oil, perhaps no industry is more susceptible to the financial decline and...more

Blank Rome LLP

The Gateway to Chapter 15: An Evolving Issue

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Chapter 15 of the United States Bankruptcy Code is a relatively recent addition to the American bankruptcy statute and it incorporates the United Nations Commission on International Trade Law Model Law on Cross-Border...more

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