If you were a CFO staring down a wall of unsecured notes maturing in eighteen months, would you automatically reach for Chapter 11? Increasingly, the answer is no. A growing number of U.S. companies are heading to London, Toronto, or Amsterdam to fix specific aspects of their balance sheets, then coming home to have U.S. courts enforce the result. This isn’t an exotic fringe tactic deployed only by offshore holding companies. Fossil Group, a public company listed on the Nasdaq and based in Texas, blazed this trail with a Part 26A restructuring in the United Kingdom in late 2025. Others have followed the same playbook in an assortment of other jurisdictions. In an elevated interest rate environment and with significant corporate debt maturities on the horizon in 2026 through 2028, selective international restructurings of this type are likely to occur with increasing frequency.
The Surgical Strike
The primary appeal of foreign restructuring is precision and efficiency. Traditional Chapter 11 is a blunt instrument: File a petition and suddenly everything is on the table—loans, bonds, trade payables, leases, contracts, pension obligations, and more—and numerous constituents are at the table. Professional fees mount quickly and litigation frequently ensues. That’s fine if the whole capital structure needs a reset or the business has systemic issues requiring the unique tools available under the Bankruptcy Code. But what if you have exactly one problem? What if it’s only the 2026 unsecured notes that are keeping you up at night?
Click here to view the full article