ABSTRACT
This chapter offers some observations from a comparative perspective highlighting significant jurisdictional similarities and differences that impact corporate rescue and employment protection during corporate insolvency in the UK and the US. The chapter also analyses the latest developments in the fields of corporate rescue and employment. The chapter analyses the latest political developments in the UK in the form of Brexit with particular emphasis on the provisions within the European Union (EU) Withdrawal Act 2018 that impact the fate of employee protection during corporate insolvency post-Brexit. The chapter also considers the latest EU Directive on Preventive Restructuring and how it may impact UK corporate rescue and employment relationships.
