News & Analysis as of

Fraudulent Transfers

Nelson Mullins Riley & Scarborough LLP

Supreme Court Limits Trustee Avoidance Powers in U.S. v. Miller - Section 106(a) Doesn’t Waive Sovereign Immunity for...

Section 106(a) Doesn’t Waive Sovereign Immunity for State-Law-Based Section 544(b) Claims - The U.S. Supreme Court has significantly curtailed bankruptcy trustees’ powers in United States v. Miller, 145 S. Ct. 839 (2025). In...more

Orrick, Herrington & Sutcliffe LLP

Colorado enacts its Voidable Transactions Act

On April 7, Colorado enacted SB 25-133, titled the Colorado Voidable Transactions Act, which amended and renamed the statute formerly known as the “Colorado Uniform Fraudulent Transfers Act.” The Act originally created a...more

Tarter Krinsky & Drogin LLP

The Supreme Court Limits A Trustee’s Rights To Recover Fraudulent Transfers Against The Internal Revenue Service

The Bankruptcy Code provides chapter 7 trustees with significant powers to liquidate and collect estate assets and pursue litigation claims, such as fraudulent transfer claims against third parties, all to increase the...more

Ballard Spahr LLP

Supreme Court: No Strong-Arming the Federal Government With State-Law Fraudulent Transfer Claims

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Recently, in the case United States v. Miller, the U.S. Supreme Court held that the sovereign immunity waiver provision in the Bankruptcy Code is jurisdictional only and does not waive the federal government’s sovereign...more

Cadwalader, Wickersham & Taft LLP

Taking Apart Section 544(b): Supreme Court Clarifies Scope of Sovereign Immunity in Avoidance Actions

On March 26, 2025, the Supreme Court held in an 8‑to‑1 decision authored by Justice Ketanji Brown Jackson that Section 106(a) of the Bankruptcy Code waives the federal government’s sovereign immunity with respect to...more

Jones Day

Ninth Circuit: No Injury to Creditors Required for Avoidance of Intentionally Fraudulent Transfer

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To assist a bankruptcy trustee or chapter 11 debtor-in-possession ("DIP") in maximizing the value of the bankruptcy estate for the benefit of all stakeholders, the Bankruptcy Code authorizes a trustee or DIP to avoid certain...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Private Equity Throws FCA Enforcement Off-Kilter

Over the last 15 years, private equity (“PE”) firms have invested hundreds of billions of dollars in the healthcare sector, infiltrating every corner of the industry from emergency rooms and labs to billing providers and...more

IR Global

Seán Dunne’s escape from bankruptcy foiled by ‘incredible’ attitude

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In the high-stakes trial, Coan et al. v. Dunne et al., Attorney Thomas H. Curran, representing Chapter 7 Trustee Richard M. Coan, successfully exposed the Irish developer Sean Dunne and his wife, Gayle Killilea’s unsuccessful...more

DLA Piper

Impactful Rulings and Cases Shaping Bankruptcy Law: 2024 Restructuring Recap

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The restructuring landscape in 2024 demonstrated dynamic shifts, with courts across jurisdictions issuing pivotal rulings that helped reshape bankruptcy law....more

King & Spalding

Second Circuit Refines Fraudulent Transfer Defense Under Bankruptcy Code’s “Safe Harbor” Provision

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On November 27, 2023, the U.S. Court of Appeals for the Second Circuit revived some of a bankruptcy litigation trustee’s fraudulent transfer claims stemming from the leveraged buyout of apparel retailer Nine West. The lawsuit...more

Nelson Mullins Riley & Scarborough LLP

United States v. Miller Oral Argument: Supreme Court Justices Seem Divided on Issues of Allowing a Trustee to Sue the IRS for...

This author previously wrote an article published in Bloomberg Law regarding the Supreme Court’s decision to take up an appeal of a decision on the Tenth Circuit Court of Appeals in United States v. Miller. In Miller, the...more

Jones Day

Imputation of Agent's Knowledge to Transferee in Bankruptcy Avoidance Litigation Defeats Good-Faith Defense

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In situations where a bankruptcy court avoids a fraudulent transfer or similar transaction, subsequent transferees who received proceeds of the avoided transaction from the initial transferee can avoid liability in certain...more

King & Spalding

Second Circuit Reinstates Fraudulent Transfer Claim Against Debtor’s Lenders

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On July 8, 2024, the U.S. Court of Appeals for the Second Circuit reversed, in a summary order, the dismissal of fraudulent transfer claims brought by the purported contract creditor of a shipping company against the shipping...more

King & Spalding

Divided Ninth Circuit Panel Reaffirms “Ponzi Scheme Presumption” of Intent to Defraud in Fraudulent Transfer Action

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On August 23, 2024, a divided panel of the U.S. Court of Appeals for the Ninth Circuit affirmed a jury’s verdict for a Chapter 7 trustee in an actual fraudulent transfer claim, which was based on the determination that...more

Proskauer Rose LLP

What Being An 'Insider' Means In Ch. 11, And Why It Matters

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After nearly a decade of historically low interest rates, many borrowers will now have to grapple with near-term maturities between 2025 and 2028 on approximately $4.9 trillion of corporate debt. While some borrowers may...more

DLA Piper

Second Circuit Rules Bankruptcy Code’s “Safe Harbor” Provision Preempts State Law Fraudulent Transfer Claims

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On September 19, 2024, the US Court of Appeals for the Second Circuit issued a summary order in which it held that the “safe harbor” provision of Section 546(e) of the Bankruptcy Code preempted a bankruptcy trustee’s state...more

Ward and Smith, P.A.

Shocker! Fraudulent Transfer Leads to Judgment Against Transferee

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The 16th Century gave plenty to the world – Leonardo da Vinci's "Mona Lisa," the Scientific Revolution, the Protestant Reformation, Michaelangelo's "David," and the Statute of Elizabeth.  That last one may be a...more

DLA Piper

Ninth Circuit Authorizes Trustees to Avoid Intentional Fraudulent Transfers Without Need to Demonstrate Creditor Harm

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In a case of first impression in the Ninth Circuit, the US Court of Appeals recently handed bankruptcy trustees a significant power by ruling in The Lovering Tubbs Trust v. Hoffman (In re O’Gorman) that a trustee can avoid...more

Gray Reed

Fraud in the Oil Patch the Modern Way

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Once upon a time a good way to commit oil patch theft was to back a truck up to the tank battery in the middle of the night, fill ‘er up, and drive off into the darkness. In re: Black Elk Energy Offshore Operations LLC shows...more

Troutman Pepper Locke

What Are Fraudulent Transfer Claims and What Defenses Exist to Such Claims? - Creditor’s Rights Toolkit

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A fraudulent transfer is an attempt to avoid a debt by improperly transferring assets to a third party, or a transfer of assets for less than fair value made while the company is insolvent or will become insolvent as a result...more

King & Spalding

Texas Bankruptcy Court Recommends Denying Summary Judgment in Case Alleging Fraudulent Transfer of PPP Funds to Make Settlement...

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On May 16, 2024, the U.S. Bankruptcy Court for the Northern District of Texas recommended that the district court largely deny cross motions for summary judgment in an action by the liquidating trust for Fresh Acquisitions,...more

Fleurinord Law PLLC

How Irrevocable Trusts Can Protect Assets from Bankruptcy & Divorce in Florida

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In the complex world of estate planning, irrevocable trusts offer a robust mechanism for protecting assets from various threats, including bankruptcy and divorce. This article delves into the specific protections offered by...more

Hudson Cook, LLP

[Webinar] CFPB Bites of the Month: The CFPB Shines Like the 4th of July - July 17th, 12:30 pm ET

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Please join Eric Johnson and Justin Hosie as they recap recent CFPB actions and enforcements, including negative equity findings from the Auto Finance Data Pilot; compliance dates for the Small Business Lending Rule; the...more

Strafford

[Webinar] Drafting Asset Purchase Agreements: Reps, Warranties, Covenants, Conditions, Indemnity, and Other Provisions - July...

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This CLE course will guide deal counsel in drafting and negotiating asset purchase agreements. The panel will discuss legal considerations when negotiating representations and warranties, indemnities, covenants, closing...more

Gray Reed

Fraud in an Oil Deal Revealed after Nine Years

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In the Estate of Larry Wayne Ewers is a reminder of a few guidelines for oil and gas investing:   Think twice before giving money to your scripture-spouting friend from church....more

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