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United Kingdom › Chapter 15 › Cross-Border

Patterson Belknap Webb & Tyler LLP

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

Patterson Belknap Webb & Tyler LLP on

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

A&O Shearman

The sun never sets on English law governed debt: reviewing the Re Prosafe SE decision

A&O Shearman on

The recent decision in Re Prosafe SE pits the principle of freedom of contract against the increasingly popular modified universalism in the cross-border restructuring and insolvency space. ...more

Hogan Lovells

First English Scheme of Arrangement Recognised in Canada under the CCAA

Hogan Lovells on

In a recent decision, the Ontario Superior Court of Justice recognised the English law schemes of arrangement of the Syncreon group under the Companies’ Creditors Arrangement Act, RSC 1985, c C-36 (“CCAA“). ...more

Jones Day

Proposed Amendments to Chapter 15 of the Bankruptcy Code

Jones Day on

On August 20, 2018, the National Bankruptcy Conference (the "NBC") submitted a letter (the "Letter") to representatives of the House Subcommittee on Regulatory Reform and the House Committee on the Judiciary that proposed...more

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