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Transatlantic Restructuring Plans in the U.S., Canada, U.K. and Netherlands
As cross-border restructurings become increasingly common, understanding how different jurisdictions approach restructuring plans is essential for practitioners advising multinational clients. This panel will examine and compare key features of restructuring frameworks in the U.S., U.K., Canada and the Netherlands, highlighting similarities, differences, and recent developments shaping international practice.
Determining the Applicable Law Governing the Effect of Insolvency on Arbitration
The intersection between insolvency and arbitration remains one of the most complex and unsettled areas of cross-border dispute resolution. This panel will examine the ongoing debate within UNCITRAL Working Group V on determining which law governs the effect of insolvency proceedings on arbitration agreements and arbitral proceedings, and how different jurisdictions approach this question in practice.
Does the U.S. Need a Scheme of Arrangement?
The U.K. Scheme of Arrangement and other international restructuring tools have attracted global attention for their flexibility and effectiveness. This panel will explore whether the U.S. should adopt a similar framework, and will analyze potential benefits, challenges and implications for debtors and creditors within the existing chapter 11 system.
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