Law firms and investors now treat bankruptcy as a global playground, with London joining the United States in attracting distressed debt cases. A Harvard Law School paper calls this a “global law of debt,” noting that New York and London lawyers shape outcomes more than national courts. The shift reshapes how debtors choose forums.

Multi-Color, a private‑equity‑backed Ohio company, illustrated the tactic by opening a $1 million New Jersey bank account and filing Chapter 11 in the state after borrowing $6 billion. Creditors branded the move cynical, but a judge accepted the manoeuvre under the code’s ambiguity. By April, the plan was approved.

Texas retailer Fossil turned to Part 26A of the UK’s 2006 Companies Act to swap $150 million of bonds that were due, avoiding a messy U.S. Chapter 11. The “stapled exchange” lifted shareholders’ equity from $80 million to $250 million, a move that required 75 percent of debt holders’ consent and later a Chapter 15 petition in Houston.

These cross‑border restructurings show that debtors can now sidestep domestic court constraints, but they also invite accusations of gamesmanship. As U.S., U.K., and other jurisdictions validate foreign proceedings, creditors and regulators must tighten scrutiny. Firms that navigate this mobile regime will shape future bankruptcy practices.