One deal, two jurisdictions – interpreting competing jurisdiction clauses
The Court of Appeal has provided comfort to the derivatives market by giving a wide, commercial interpretation to an exclusive English jurisdiction clause.
Will Singapore become an international centre of debt restructuring?
A comparative analysis of Singapore's bold insolvency reforms
Singapore has made significant reforms to its insolvency and restructuring legislation in recent times. These reforms have significantly enhanced the power of restructuring tools available in Singapore, through what has been described as a unique hybrid regime combining the flexibility of the English regime with the powerful arsenal of US Chapter 11 provisions.
Our financial restructuring and insolvency partner Noel McCoy has written a special report, first published by INSOL International. This paper analyses Singapore’s legislative reforms comparative to England and Wales and the US. It also analyses the potential impact of these legislative changes, with particular emphasis on enforceability and recognition in the US, England and Wales and the Asia-Pacific region.
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