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    Tenth Circuit: Bankruptcy Trustee May Recover Only the Actual Property (Not Proceeds) Fraudulently Transferred to Subsequent Transferees
    2020-12-11

    The ability of a bankruptcy trustee to avoid certain transfers of a debtor's property and to recover the property or its value from the transferees is an essential tool in maximizing the value of a bankruptcy estate for the benefit of all stakeholders. However, a ruling recently handed down by the U.S. Court of Appeals for the Tenth Circuit could, if followed by other courts, curtail a trustee's avoidance and recovery powers. In Rajala v. Spencer Fane LLP (In re Generation Resources Holding Co.), 964 F.3d 958 (10th Cir. 2020), reh'g denied, No.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Jones Day, Tenth Circuit, U.S. Court of Appeals
    Authors:
    Dan T. Moss , Mark G. Douglas
    Location:
    USA
    Firm:
    Jones Day
    Bolstering the Majority Rule: Bankruptcy Court Holds that Adjudication of Avoidance Liability Is Prerequisite to Disallowance of Transferee's Claim Under Section 502(d)
    2020-08-13

    The U.S. Bankruptcy Court for the Eastern District of North Carolina recently added some weight to the majority rule on an issue that has long divided bankruptcy and appellate courts. In In re Southern Produce Distributors, Inc., 2020 WL 1228719 (Bankr. E.D.N.C. Mar.

    Filed under:
    USA, North Carolina, Insolvency & Restructuring, Litigation, Jones Day, Title 11 of the US Code
    Authors:
    Daniel J. Merrett (Dan) , Mark G. Douglas
    Location:
    USA
    Firm:
    Jones Day
    Resurgence of Bifurcation Approach to Priority of Straddle Year Taxes in Bankruptcy
    2020-02-15

    A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than debts incurred by the estate, which are generally treated as priority administrative expenses. However, this seemingly straightforward principle is sometimes difficult to apply in cases where a debt technically "arose" or "was incurred" prepetition, but does not became payable until sometime during the bankruptcy case. A ruling recently handed down by the U.S.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Tax, Jones Day, Internal Revenue Service (USA), US Department of Justice
    Authors:
    Brad B. Erens , Mark G. Douglas
    Location:
    USA
    Firm:
    Jones Day
    Independence Day: Australian Court Refuses to Remove Liquidators
    2019-10-09

    In Short

    The Situation: Should liquidators be removed under section 90-15 of the Insolvency Practice Schedule (Corporations) in circumstances where they engaged in preappointment discussions with a secured creditor, allegedly failed to investigate the company's affairs promptly, and retained the company's preappointment solicitors?

    Filed under:
    Australia, Insolvency & Restructuring, Litigation, Jones Day
    Authors:
    Maria Yiasemides , Roger Dobson , Evan J. Sylwestrzak
    Location:
    Australia
    Firm:
    Jones Day
    "Rejection" of a Trademark License in Bankruptcy Is a Breach, Not a Rescission
    2019-05-29

    Bankruptcy protection under Section 365 does not give brand owners/debtor-licensors the unilateral right to rescind trademark licensing agreements.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Trademarks, Jones Day, First Circuit, U.S. Court of Appeals
    Authors:
    Ben Rosenblum
    Location:
    USA
    Firm:
    Jones Day
    Short-Squeeze Risks Loom Again in CDS Markets
    2019-01-11

    In Short:

    The Situation: Fears of a potential short-squeeze in the upcoming Sears CDS auction have kicked off disputes in a variety of venues.

    The Result: One of these disputes caused the fourth-ever convening of an ISDA CDS Determinations Committee external review panel and another made its way before the Sears bankruptcy court.

    Filed under:
    USA, Derivatives, Insolvency & Restructuring, Jones Day, Credit default swap, International Swaps and Derivatives Association
    Authors:
    George J. Cahill , Jayant W. Tambe
    Location:
    USA
    Firm:
    Jones Day
    A Lesson in DIP Financing Due Diligence
    2018-06-08

    The Bankruptcy Code contains an array of provisions designed to encourage lenders to provide debtor-in-possession ("DIP") financing in chapter 11 cases, including authorization of "superpriority" administrative expense claims and "priming" liens designed to ensure that DIP loans are repaid. However, as illustrated by a ruling recently handed down by the U.S.

    Filed under:
    USA, Illinois, Insolvency & Restructuring, Litigation, Jones Day, Due diligence, United States bankruptcy court
    Authors:
    T. Daniel Reynolds (Dan)
    Location:
    USA
    Firm:
    Jones Day
    Cross-Border Bankruptcy Update: COMI Migration and Illegitimate COMI Manipulation Distinguished
    2017-11-22

    With the significant increase in cross-border bankruptcy and insolvency filings in the 43 nations or territories that have adopted the UNCITRAL Model Law on Cross-Border Insolvency (the "Model Law"), including the U.S., the incidence of "COMI migration"—the shifting of a debtor’s "center of main interests" ("COMI") to a country with more favorable insolvency laws—has also increased. As demonstrated by a ruling handed down by the U.S.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Jones Day, UNCITRAL, US Securities and Exchange Commission, United States bankruptcy court, US District Court for SDNY
    Authors:
    Dan T. Moss , Mark G. Douglas
    Location:
    USA
    Firm:
    Jones Day
    Without WARN-ing: Third Circuit Clarifies WARN Act's Unforeseen Business Circumstances Exception
    2017-08-30

    What Happened: The Third Circuit Court of Appeals joined five other circuits in holding that the unforeseen business circumstances exception excused WARN notice where an event outside the employer's control that would trigger layoffs was possible but not probable to occur.

    The Larger Landscape: While the Fifth, Sixth, Seventh, Eighth, and Tenth Circuits have also adopted a probability standard for determining when the unforeseen business circumstances exception applies, the other circuits have not yet ruled on the issue.

    Filed under:
    USA, Employment & Labor, Insolvency & Restructuring, Litigation, Jones Day, Bankruptcy, Liquidation, United States bankruptcy court, Third Circuit
    Location:
    USA
    Firm:
    Jones Day
    In Brief: Court Rules Against Lyondell Litigation Trustee on LBO Fraudulent Conveyance Claims
    2017-05-31

    In Weisfelner v. Blavatnik(In re Lyondell Chemical Company), 2017 BL 131876 (Bankr. S.D.N.Y. Apr. 21, 2017), the bankruptcy court presiding over the chapter 11 case of Lyondell Chemical Company ("Lyondell") handed down a long-anticipated opinion in the protracted litigation concerning the failed 2007 merger of Lyondell with Basell AF S.C.A. ("Basell"), a Netherlands-based petrochemical company.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Jones Day, Bankruptcy, Fraud, United States bankruptcy court
    Authors:
    Mark G. Douglas
    Location:
    USA
    Firm:
    Jones Day

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