U.S. Bankruptcy Rulings May be Applicable in Cases in that Affect Residents in the UK
The Court of Appeal recently ruled in the case of a trust created by Eurofinance that British courts could recognize overseas insolvency proceedings made by courts in the United States. After the collapse of Lehman Brothers and the Bernard Madoff scheme, financial analysts say that U.S. bankruptcy court rulings growing in sync with rulings in the UK may become a reality.
If the move had been made sooner, the Financial Times says that victims of the Madoff plot in the UK could have been received more money as retribution for their losses. In the case of Lehman, trustees in the United States could seek support from the UK courts in enforcing U.S. bankruptcy judgments.
John Verrill of Dundas & Wilson, a law firm involved in the Eurofinance case, said the removal of the requirement for duplicate actions in either the United States or the United Kingdom was an important change. Before this, U.S. bankruptcy judgments were not enforceable in the UK unless a separate UK action had begun on the same grounds, the Times notes
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