London calling—crossing the Atlantic to restructure in England?

A&O Shearman’s US and London Restructuring teams compare Chapter 11 with the English Part 26A restructuring plan, highlighting the UK regime’s speed, lower costs, cross-class cram-down flexibility, broad third-party releases and ability to target selected creditor classes, while noting Chapter 11’s advantages in automatic stays, DIP financing, executory contracts and asset sales, and pointing to Argo Blockchain, Fossil and New Fortress Energy as examples of US-connected companies using English plans followed by Chapter 15 recognition.

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