Cross-border insolvency proceedings and cramdown

The PodChat cross-border series continues with colleagues from Berlin, London, Luxembourg, Paris and the US discussing the current status of the insolvency practice in these regions. As we experience an increase in insolvency proceedings, financial restructurings continue to rise and the various industries take a hit. What does the debtor need to file for insolvency proceedings in each jurisdiction? What about cross-class cramdown? Some regions are handling this quite similarly while others have different obstacles to overcome.