Nava Hazan and Susan Kelly have written an article for the newsletter of the American Bankruptcy Institute’s Business Reorganization Committee about how the UK and US have become the two main jurisdictions where debtors outside of such jurisdictions have been able to successfully restructure their businesses, due to the flexibility of the UK and US’ legal systems and their shared focus on reorganization, as opposed to liquidation.

The article was in two parts. The first part was related to the UK perspective and described the use of the Scheme of Arrangement under the Companies Act 2006 (click here to read Part 1, which was the subject of a previous blog).  The second part relates to the US system and describes how such system may be used by a foreign debtor to restructure its business.