Business Credit Magazine February 2014 | Page 44

I n t e r n at i o n a l F e at u r e Getting To Know You A Primer on Canadian Bankruptcy J a c o b Ba r r o n 2009 was to Canada what 2005 was to the U.S., at least in terms of bankruptcy. A previously passed sweeping reform to the Bankruptcy Code went into effect in the fall, in September 2009 for Canada and October 2005 for the U.S., preceded by a massive increase in filings that colored the statistics for the whole year. Additionally, just as the U.S.-approved Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA) was considered a tightening of the bankruptcy rules, so were Canada’s amendments to its governing legislations. In both instances, the insolvent, both consumer and business, rushed to the courts to take advantage of the more lenient laws before they expired. The total number of insolvencies in Canada in September 2009 was 28.4% higher than the month before, while liquidations, simply called bankruptcies in Canada, increased by 29.1%. Bankruptcy proceedings are currently stabilizing in Canada, but the new rules have affected proceedings in a number of different ways. When an insolvent debtor becomes a bankrupt debtor in Canada, U.S. creditors and their companies doing business with them may face a number of unique differences between the two neighboring nations’ bankruptcy systems. Instead of one governing Code in the U.S., Canada has multiple pieces of legislation governing various portions of the proceedings. An unprepared creditor unfamiliar with the occasionally subtle nuances of Canada’s bankruptcy system may wind up missing something, and missing their money in return. Les Trois Amis A discussion of Canadian bankruptcy as it relates to creditors begins and ends with the nation’s three bankruptcy laws. “We have three legislations that deal with bankruptcy,” said Hubert Sibre, a partner at BCF LLP in Montreal. “One is the Winding Up Act [technically named the Companies Winding Up Act], then we have the Bankruptcy and Insolvency Act (BIA) and then we have the CCAA, the Companies’ Creditors Arra