Beyond Chapter 11: How US companies are using UK restructuring plans

Craig Martin, David Manson, Philip Povey, Erik Stier, and Adam Plainer of DLA Piper explain that US companies are increasingly using UK restructuring plans as a flexible, chapter 15-recognisable alternative to chapter 11 to implement targeted liquidity management exercises, illustrated by Fossil Group’s use of a UKRP to restructure a single tranche of New York law debt through manufactured UK jurisdiction, lower voting thresholds, and cramdown powers.

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