Cross-Border Strategy: O Canada — U.S. Companies Look North for Main Insolvency Proceedings
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This article examines the emerging trend of U.S.-based companies with Canadian ties initiating primary insolvency proceedings in Canada and seeking recognition in the United States under Chapter 15 of the U.S. Bankruptcy Code. As described herein, this two-step strategy enables debtors to take advantage of the flexibility and efficiency of Canadian restructuring regimes, while securing key U.S. bankruptcy protections.

A Strategic Shift in Cross-Border Insolvency

Filed under:
Canada, USA, Company & Commercial, Insolvency & Restructuring, Litigation, Freshfields, Insolvency, RBC, Sunac China Holdings Ltd, Bentley, Financial services corporate, Real Estate
Authors:
Madlyn Primoff , Alexander Rich
Location:
Canada, USA
Firm:
Freshfields