Cross Border Restructurings – How to Evaluate the Best Insolvency Regime to Accomplish Your Restructuring Goals
There have been a number of recent amendments to the insolvency regimes in the EU and in the UK which are intended to replicate many of the attributes of the US Bankruptcy Code and offer global companies the opportunity to implement a comprehensive restructuring without having to commence a US chapter 11 proceeding.
This program covers how successful those amendments have been to date, and compares and contrasts the main features of the various regimes which are essential for global companies to understand in order to make an informed decision about which jurisdiction will best allow parties to achieve their goals.
Topics will include:
- Choosing among the various (and competing) jurisdictions. Which of the new jurisdictions will become the “challenger jurisdictions” in years to come;
- Ability to cram down classes of creditors in a restructuring;
- Ability to obtain financing and operate during a proceeding; and
- Managing the process across multiple jurisdictions
