1. Overview
1.1 Where would you place your jurisdiction on the spectrum of debtor- to creditor-friendly jurisdictions?
The United States can most accurately be described as reorganisation-friendly, as the Bankruptcy Code is designed to facilitate a fresh start for a debtor, while maximising recoveries for all stakeholders, including creditors.
On the one hand, the United States could be considered comparatively debtor-friendly in that management is typically permitted to retain operating…