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ARTICLE · 05 FEBRUARY 2026

Has The Texas Two-Step Become The Thames Two-Step?

K&L Gates
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In the first of its kind, a US company with no prior connection to the United Kingdom, has financially restructured via a Part 26A Companies Act (UK) Restructuring Plan (the RP), in respect of which it also achieved Chapter 15 recognition.

United StatesInsolvency/Bankruptcy/Re-Structuring
Sonya Van de Graaff
Sonya Van de Graaff
Robert Honeywell
Robert Honeywell

Executive Summary

In the first of its kind, a UScompany with no prior connection to the United Kingdom, has financially restructured via a Part 26A Companies Act (UK) Restructuring Plan (the RP), in respect of which it also achieved Chapter 15 recognition.

Whilst the English restructuring market understandably applauds the outcome, the case raises some probing questions from the perspective of USjurisprudence, including the limits of legitimate forum shopping, due process and circumvention of the Ch.11 principle against third-party releases. A more complex but equally important question is whether certain aspects of the case might properly be construed as a work around the controversial 'Texas Two-Step'.

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