Not so welcoming? United States cross-border insolvency assistance

Examines the recognition of and assistance for foreign insolvency proceedings offered by the US courts under the US Code Title 11 Ch.15 (Bankruptcy Code), with particular reference to the approach to determining a centre of main interests, leading to refusal of recognition of Cayman Islands proceedings, in Re Basis Yield Alpha Fund (Master) and Re Bear Stearns High-Grade Structured Credit Strategies Master Fund Ltd (In Provisional Liquidation). Suggests that the approach under Ch.15 is more restrictive than the previous approach in the US, noting examples from case law under the previous provisions.