Ireland: Taking flight: how foreign law restructuring proceedings have the potential to compromise english law governed debt

Partners, Fiona MacAdam and William Greensmyth and Associates, Siobhan Sheridan and Keith Hyland, together with Stefanie Wilkins of South Square Chambers, examine the conclusions that the Irish Court reached in Norwegian Air concerning how Irish insolvency proceedings might be recognised in England and Wales under section 426 of the English Insolvency Act. The article considers how this approach might potentially be adopted to allow a Cayman Islands scheme of arrangement within the new restructuring officer regime to be recognised and enforced in England and Wales.

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