Abstract

European insolvency legislation is changing. The EU has introduced a regulation defining primary jurisdiction in EU cross-border restructuring. U.S. capital and professionals are influencing European restructuring and U.S. turnaround firms have crossed the Atlantic. So is the Europe Union adopting U.S. process across its 25-member states? While the words may be familiar, there are elephant traps for the unwary! Europe is neither a level playing field nor a uniform one.

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