Entradas
De acuerdo a la ONU, el rechazo de la Corte Suprema por los fondos buitre "puede traer consecuencias para el sistema financiero internacional". La Conferencia de las Naciones Unidas sobre Comercio y Desarrollo del organismo multilateral (UNCTAD, por sus siglas en inglés) así lo advirtió en un duro documento.
El rechazo de la Corte Suprema de EEUU de tomar la apelación argentina en el llamado "juicio del siglo", de acuerdo al ente, "establece un antecedente legal con consecuencias profundas para el sistema financiero internacional".
A mediados de mes, la Corte Suprema estadounidense rechazó una apelación argentina y dejó en firme una sentencia del juez Thomas Griesa que ordena a Argentina pagar a los fondos litigantes tenedores de deuda no reestructurada u$s 1.300 millones que, con intereses, suma u$s 1.500 millones. "En este contexto caótico, la formulación de normas y principios globales y armoniosos que guíen las reestructuraciones ha devenido de vital importancia", reza un comunicado de la UNCTAD.
El texto recuerda que la UNCTAD ha abogado desde larga data porque se elabore un mecanismo de guía a las reestructuraciones, y anuncia que está actualmente trabajando en un "proyecto".
El organismo considera que la crisis provocada por los "fondos buitres" contra Argentina "amenaza con tener profundas consecuencias para todos el sistema financiero internacional". "Las consecuencias de la decisión del Tribunal Supremo de Estados Unidos del 16 de junio de declinar la apelación Argentina contra la decisión que le obliga a pagar u$s 1.330 millones, resuena más allá de las fronteras de Argentina y Estados Unidos".
La UNCTAD considera que el hecho de que se permita entregar información privilegiada a estos fondos sobre el patrimonio que Argentina ostenta en todo el mundo "podría provocar que se dieran otros casos similares de interpretaciones en base a leyes de Estados Unidos, Gran Bretaña o otras".
La agencia de Naciones Unidas considera que la decisión podría tener "profundas consecuencias para el sistema financiero internacional" y provocar que las reestructuraciones de deuda sean aún más difíciles "al forzar a las instituciones de servicios financieros a proveer información confidencial que podría erosionar la inmunidad soberana", concluye.
DOCUMENTO ORIGINAL EN INGLES
Global and systemic implications of United States Supreme Court rulings in favour of
hedge funds over Argentina on 2001 defaulted bonds
The United States Supreme Court issued a ruling on 16 June 2014 declining to hear Argentina's
appeal against a lower New York court decision that had ordered it to pay suing hedge funds $1.33
billion, which is principal plus interest for holdout bonds. This was followed shortly by another
decision by the Supreme Court to order the relevant financial institutions of the United States of
America to turn over information to these hedge funds about assets that Argentina holds worldwide,
including accounts held by entities of the Government of Argentina and by individual officials1.
These two rulings targeted at Argentina's 2005 and 2010 debt swaps, in the wake of its catastrophic
2001-2002 default on $100 billion bonds governed by New York law, resonate well beyond the
borders of Argentina and the United States. The rulings are a resounding victory for the specific
hedge funds that have held out on Argentine debt swaps. They also open the door for other
"vulture" funds and holdout investors to come forward to request full payment on Argentine bonds,
estimated at around $15 billion. If Argentina pays the holdout bond holders, it must extend full
payment to the bond holders that accepted the 2005 or 2010 debt swaps, due to a "Rights upon
Future Offers" clause in its law. This would amount to an estimated cost of over US$120 billion2. In
fact, the rulings could open floodgates to other similar cases depending on interpretations given by
courts under New York law, British law or other laws. Copycats will abound.
But they also set legal precedents which could have profound consequences for the international
financial system:
First, by removing financial incentives for creditors to participate in orderly debt workouts,
the rulings will make future debt restructuring even more difficult, in particular for
outstanding bonds without a Collective Action Clause, the actual amount of which is unknown
but is likely to be large.
Second, obligating third-party financial institutions to provide information about assets of
sovereign borrowers will have a significant impact on the international financial system as it
forces financial service institutions to provide confidential information on the sovereign
borrower's global financial transactions to facilitate the enforcement of debt contracts for the
creditors.
Third, the ruling will erode sovereign immunity.
A setback for debt restructuring
After defaulting on its $100 billion sovereign bonds in 2001, Argentina offered debt swaps in 2005
and in 2010. Investors holding about 93 per cent of the old bonds participated in these debt swaps.
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
1 de 4 25/06/2014 12:34 p.m.© 2013 UNCTAD
The Congress of Argentina passed a law in February 2005 that forbade the Government to make
payments on any bonds not tendered, to later reopen the exchange or to settle with
non-participating creditors one by one on the side. However, a handful of hedge funds purchased
the bonds after the default when they were at deep discounts. Since then, they have repeatedly
demanded to be paid at 100 per cent of their face value. This is considered by many as predatory.
For example, NML Capital purchased the majority of their Argentine bonds from June-November
2008, paying an estimated $48.7 million for over $220 million in defaulted bonds, a price of just
over 20 cents on the dollar3.
According to estimates by Morgan Stanley, bond holders who accepted the 2005 offer have received
returns of about 90 per cent4 thanks in particular to a coupon linked to gross domestic product
growth, which significantly increased the amount actually received. In response, the holdout bond
holders led by NML Captial changed tactics and took out law suits (based on the pari passu, or equal
treatment, clause in bond contracts) in New York's lower court which would tie any future payments
on restructured bonds to payment in full to holdout bond holders This was an unheard of
interpretation of the clause which shocked even veterans in the debt restructuring world. However,
on 18 November 2013, the United States Second Circuit Court of Appeals ruled in favour of NML
Capital. Argentina appealed the ruling to the United States Supreme Court. With the Supreme Court
leaving the lower court rulings intact, it has created a precedent for awarding holdout creditors and
penalizing creditors who participated in a debt restructuring.
Since the Argentine default, there has been a more prevalent introduction of the Collective Action
Clause in bond contracts which has the potential of restricting the likelihood of a small number of
creditors holding out on debt restructuring. However, it is important to note that existing bonds
without Collective Action Clause will take years to expire. This means that, with the Supreme Court
rulings, the world has limited tools to initiate debt restructuring for bonds with a pari passu clause
and without Collective Action Clause. The Supreme Court ruling has given bond holders a strong
weapon to get full payments. As stated in the recently published International Monetary Fund (IMF)
paper on debt restructuring, "in essence, the [United States] courts have interpreted a 'boiler plate
provision' of these contracts (the pari passu clause) as requiring a sovereign debtor to make full
payment on a defaulted claim (in this case, held by the secondary market purchaser) if it makes any
payments on the restructured bonds"5.
Given such consequences, the Governments of France and Germany supported Argentina in its legal
struggle. Economists such as Joseph Stiglitz and Anne Kruger petitioned against the hedge funds.
Obliging financial institutions to assist debt collectors
The Second Circuit also rules that third parties (banks in this case) who make payments on behalf of
the Government of Argentina to bond holders which participated in the two debt swaps will be
punished and viewed and treated as being in contempt of law if they continue to make such
payments and holdouts are paid in full. On top of this, the second ruling of the Supreme Court
confirmed NML Capital's request that banks involved in handling the payment of Argentine bond
holders must turn over information to holdout bond holders on assets that Argentina holds
worldwide. Obliging financial institutions to provide information about assets of sovereign
borrowers' assets worldwide will have significant impact on the international financial system as it
forces financial service providers to provide confidential information on the sovereign borrower's
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
2 de 4 25/06/2014 12:34 p.m.global financial transactions to facilitate enforcement of debt contracts on behalf of the creditors.
Third parties have been dragged from the wings to centre stage. In addition, it also seems they are
obliged to assist holdout bond holders in reclaiming their debt. Once again, exchange holders are
punished and holdouts are rewarded.
Justice Ruth Bader Ginsburg, a member in the Supreme Court's group of justices deciding the case,
asked: "By what authorization does a court in the United States become a 'clearinghouse for
information' about any and all property held by Argentina abroad?6" By setting this legal precedent,
it would not be surprising to see changes in the financial market and ways to aid creditors in
enforcing contracts and punishing borrowers.
Erosion of sovereign immunity
The ruling does not only impact the financial service providers involved, it also severely erodes
sovereign immunity and is not in compliance with the United States Foreign Sovereign Immunities
Act. The Government of the United States filed a brief in favour of Argentina and stated that a ruling
in favour of bond holders would harm international relations and could provoke "reciprocal adverse
treatment of the United States in foreign courts"7. An official representing the Administration
cautioned at the Court that "the United States would be gravely concerned about an order of a trial
court in a foreign country, entered at the behest of a private person, seeking to establish a
clearinghouse in that country of all the United States' assets"8. However, the Chief Justice of the
United States Supreme Court did not seem to feel any apprehension. In response to concern of the
Government of the United States on non-compliance with the Immunities Act, the Justice advised
the Government to amend the Act.
With the Supreme Court ruling, the likelihood of aggressive holdout investors snatching assets of
defaulted sovereigns might increase. In 2012, NML Capital detained an Argentine navy vessel in
Ghana as part of its effort to gain repayment on the defaulted securities.
Following an Argentine proposal to pay exchange bond holders in Argentina under Argentine law on
17 June, one day after the Supreme Court rulings, the United States Second Circuit Court of Appeals
ruled that this kind of act is in violation of the rulings and proceedings now in place in the Southern
District of New York.
Restating the case for a sovereign debt workout mechanism
The United States Supreme Court rulings have once again demonstrated what can happen in the
absence of an international debt workout mechanism. This vacuum has led to fragmentation of legal
forums, thereby creating inconsistency and unpredictability. Different courts have very different
interpretations of the same contractual clause and can impose a wide array of rulings. Politics and
interests groups can impact on the outcome of rulings and debt restructurings, compromising
consistency and fairness.
The rulings have made future debt restructuring much more difficult as debtors are left with only
moral suasion and foreign relations as weapons to encourage creditor coordination. They have also
strengthened the hand of creditors even though their behaviour can be among the underlying causes
of debt crises.
The June 2014 IMF Policy Paper entitled "The Fund's lending framework and sovereign debt -
preliminary considerations" and its annexes (in a separate paper) reviewed the lessons of past debt
restructurings. However, when it comes to possible directions for reform, the proposals are to
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
3 de 4 25/06/2014 12:34 p.m.maintain a market-based approach (based on debt contracts) and debt reprofiling - extending debt
maturity - based on the IMF's judgement that an unsustainable debt situation exists. Debt
reprofiling has the potential to trigger credit default swaps and is viewed by some as a debt
restructuring. One wonders whether the IMF is best positioned to give timely and fair judgements
and how unsustainable debt could eventually be restructured when the world does not possess
sufficient tools to deal with the problems encountered so far. To rely on the market approach under
which different courts are to interpret clauses of the debt contracts as the United States Supreme
Court has done would lead to outcomes with "broad systemic implications", just as the IMF warned.
In this chaotic context, the formulation of global and harmonious rules and principles guiding
sovereign debt restructurings has become of paramount importance. This is why UNCTAD has been
a long-standing advocate of a sovereign debt workout mechanism and is currently working on a
project financed by the Government of Norway to further clarify how it could work in practice. The
list of general principles and issues identified thus far by a group of experts under the project
includes:
Standstill/stay of litigation
Debt thresholds and indicators
Transparency
Comprehensiveness and seniority (equity among creditors, collective action issues)
Legitimacy
Impartiality (institutional)
Institutional oversight and the relation between international and domestic levels.
1United States, Supreme Court of the United States, 2013, Syllabus, Republic of Argentina v. NML
Capital.
2Wall Street Journal, 2014, Argentina wants to continue paying its debts: but they won't let it, 21
June.
3A Phillips and J Johnston, 2013, Argentina vs. the vultures: What you need to know, 2 April, Center
for Economic and Policy Research.
4D Benson, 2012, Billionaire hedge funds snub 90% returns, Bloomberg News, 23 January.
5IMF, 2014, The Fund's lending framework and sovereign debt - preliminary considerations, IMF
Policy Paper, June.
6United States, Supreme Court of the United States, 2013, Syllabus, Republic of Argentina v. NML
Capital.
7United States, United States Court of Appeals for the Second Circuit, 2013, Brief for the United
States of America as amicus curiae.
8New York Times, 2014, Argentina's debt appeal is rejected by Supreme Court, 16 June.
News
There are no items to show.
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
4 de 4
El rechazo de la Corte Suprema de EEUU de tomar la apelación argentina en el llamado "juicio del siglo", de acuerdo al ente, "establece un antecedente legal con consecuencias profundas para el sistema financiero internacional".
A mediados de mes, la Corte Suprema estadounidense rechazó una apelación argentina y dejó en firme una sentencia del juez Thomas Griesa que ordena a Argentina pagar a los fondos litigantes tenedores de deuda no reestructurada u$s 1.300 millones que, con intereses, suma u$s 1.500 millones. "En este contexto caótico, la formulación de normas y principios globales y armoniosos que guíen las reestructuraciones ha devenido de vital importancia", reza un comunicado de la UNCTAD.
El texto recuerda que la UNCTAD ha abogado desde larga data porque se elabore un mecanismo de guía a las reestructuraciones, y anuncia que está actualmente trabajando en un "proyecto".
El organismo considera que la crisis provocada por los "fondos buitres" contra Argentina "amenaza con tener profundas consecuencias para todos el sistema financiero internacional". "Las consecuencias de la decisión del Tribunal Supremo de Estados Unidos del 16 de junio de declinar la apelación Argentina contra la decisión que le obliga a pagar u$s 1.330 millones, resuena más allá de las fronteras de Argentina y Estados Unidos".
La UNCTAD considera que el hecho de que se permita entregar información privilegiada a estos fondos sobre el patrimonio que Argentina ostenta en todo el mundo "podría provocar que se dieran otros casos similares de interpretaciones en base a leyes de Estados Unidos, Gran Bretaña o otras".
La agencia de Naciones Unidas considera que la decisión podría tener "profundas consecuencias para el sistema financiero internacional" y provocar que las reestructuraciones de deuda sean aún más difíciles "al forzar a las instituciones de servicios financieros a proveer información confidencial que podría erosionar la inmunidad soberana", concluye.
DOCUMENTO ORIGINAL EN INGLES
Global and systemic implications of United States Supreme Court rulings in favour of
hedge funds over Argentina on 2001 defaulted bonds
The United States Supreme Court issued a ruling on 16 June 2014 declining to hear Argentina's
appeal against a lower New York court decision that had ordered it to pay suing hedge funds $1.33
billion, which is principal plus interest for holdout bonds. This was followed shortly by another
decision by the Supreme Court to order the relevant financial institutions of the United States of
America to turn over information to these hedge funds about assets that Argentina holds worldwide,
including accounts held by entities of the Government of Argentina and by individual officials1.
These two rulings targeted at Argentina's 2005 and 2010 debt swaps, in the wake of its catastrophic
2001-2002 default on $100 billion bonds governed by New York law, resonate well beyond the
borders of Argentina and the United States. The rulings are a resounding victory for the specific
hedge funds that have held out on Argentine debt swaps. They also open the door for other
"vulture" funds and holdout investors to come forward to request full payment on Argentine bonds,
estimated at around $15 billion. If Argentina pays the holdout bond holders, it must extend full
payment to the bond holders that accepted the 2005 or 2010 debt swaps, due to a "Rights upon
Future Offers" clause in its law. This would amount to an estimated cost of over US$120 billion2. In
fact, the rulings could open floodgates to other similar cases depending on interpretations given by
courts under New York law, British law or other laws. Copycats will abound.
But they also set legal precedents which could have profound consequences for the international
financial system:
First, by removing financial incentives for creditors to participate in orderly debt workouts,
the rulings will make future debt restructuring even more difficult, in particular for
outstanding bonds without a Collective Action Clause, the actual amount of which is unknown
but is likely to be large.
Second, obligating third-party financial institutions to provide information about assets of
sovereign borrowers will have a significant impact on the international financial system as it
forces financial service institutions to provide confidential information on the sovereign
borrower's global financial transactions to facilitate the enforcement of debt contracts for the
creditors.
Third, the ruling will erode sovereign immunity.
A setback for debt restructuring
After defaulting on its $100 billion sovereign bonds in 2001, Argentina offered debt swaps in 2005
and in 2010. Investors holding about 93 per cent of the old bonds participated in these debt swaps.
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
1 de 4 25/06/2014 12:34 p.m.© 2013 UNCTAD
The Congress of Argentina passed a law in February 2005 that forbade the Government to make
payments on any bonds not tendered, to later reopen the exchange or to settle with
non-participating creditors one by one on the side. However, a handful of hedge funds purchased
the bonds after the default when they were at deep discounts. Since then, they have repeatedly
demanded to be paid at 100 per cent of their face value. This is considered by many as predatory.
For example, NML Capital purchased the majority of their Argentine bonds from June-November
2008, paying an estimated $48.7 million for over $220 million in defaulted bonds, a price of just
over 20 cents on the dollar3.
According to estimates by Morgan Stanley, bond holders who accepted the 2005 offer have received
returns of about 90 per cent4 thanks in particular to a coupon linked to gross domestic product
growth, which significantly increased the amount actually received. In response, the holdout bond
holders led by NML Captial changed tactics and took out law suits (based on the pari passu, or equal
treatment, clause in bond contracts) in New York's lower court which would tie any future payments
on restructured bonds to payment in full to holdout bond holders This was an unheard of
interpretation of the clause which shocked even veterans in the debt restructuring world. However,
on 18 November 2013, the United States Second Circuit Court of Appeals ruled in favour of NML
Capital. Argentina appealed the ruling to the United States Supreme Court. With the Supreme Court
leaving the lower court rulings intact, it has created a precedent for awarding holdout creditors and
penalizing creditors who participated in a debt restructuring.
Since the Argentine default, there has been a more prevalent introduction of the Collective Action
Clause in bond contracts which has the potential of restricting the likelihood of a small number of
creditors holding out on debt restructuring. However, it is important to note that existing bonds
without Collective Action Clause will take years to expire. This means that, with the Supreme Court
rulings, the world has limited tools to initiate debt restructuring for bonds with a pari passu clause
and without Collective Action Clause. The Supreme Court ruling has given bond holders a strong
weapon to get full payments. As stated in the recently published International Monetary Fund (IMF)
paper on debt restructuring, "in essence, the [United States] courts have interpreted a 'boiler plate
provision' of these contracts (the pari passu clause) as requiring a sovereign debtor to make full
payment on a defaulted claim (in this case, held by the secondary market purchaser) if it makes any
payments on the restructured bonds"5.
Given such consequences, the Governments of France and Germany supported Argentina in its legal
struggle. Economists such as Joseph Stiglitz and Anne Kruger petitioned against the hedge funds.
Obliging financial institutions to assist debt collectors
The Second Circuit also rules that third parties (banks in this case) who make payments on behalf of
the Government of Argentina to bond holders which participated in the two debt swaps will be
punished and viewed and treated as being in contempt of law if they continue to make such
payments and holdouts are paid in full. On top of this, the second ruling of the Supreme Court
confirmed NML Capital's request that banks involved in handling the payment of Argentine bond
holders must turn over information to holdout bond holders on assets that Argentina holds
worldwide. Obliging financial institutions to provide information about assets of sovereign
borrowers' assets worldwide will have significant impact on the international financial system as it
forces financial service providers to provide confidential information on the sovereign borrower's
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
2 de 4 25/06/2014 12:34 p.m.global financial transactions to facilitate enforcement of debt contracts on behalf of the creditors.
Third parties have been dragged from the wings to centre stage. In addition, it also seems they are
obliged to assist holdout bond holders in reclaiming their debt. Once again, exchange holders are
punished and holdouts are rewarded.
Justice Ruth Bader Ginsburg, a member in the Supreme Court's group of justices deciding the case,
asked: "By what authorization does a court in the United States become a 'clearinghouse for
information' about any and all property held by Argentina abroad?6" By setting this legal precedent,
it would not be surprising to see changes in the financial market and ways to aid creditors in
enforcing contracts and punishing borrowers.
Erosion of sovereign immunity
The ruling does not only impact the financial service providers involved, it also severely erodes
sovereign immunity and is not in compliance with the United States Foreign Sovereign Immunities
Act. The Government of the United States filed a brief in favour of Argentina and stated that a ruling
in favour of bond holders would harm international relations and could provoke "reciprocal adverse
treatment of the United States in foreign courts"7. An official representing the Administration
cautioned at the Court that "the United States would be gravely concerned about an order of a trial
court in a foreign country, entered at the behest of a private person, seeking to establish a
clearinghouse in that country of all the United States' assets"8. However, the Chief Justice of the
United States Supreme Court did not seem to feel any apprehension. In response to concern of the
Government of the United States on non-compliance with the Immunities Act, the Justice advised
the Government to amend the Act.
With the Supreme Court ruling, the likelihood of aggressive holdout investors snatching assets of
defaulted sovereigns might increase. In 2012, NML Capital detained an Argentine navy vessel in
Ghana as part of its effort to gain repayment on the defaulted securities.
Following an Argentine proposal to pay exchange bond holders in Argentina under Argentine law on
17 June, one day after the Supreme Court rulings, the United States Second Circuit Court of Appeals
ruled that this kind of act is in violation of the rulings and proceedings now in place in the Southern
District of New York.
Restating the case for a sovereign debt workout mechanism
The United States Supreme Court rulings have once again demonstrated what can happen in the
absence of an international debt workout mechanism. This vacuum has led to fragmentation of legal
forums, thereby creating inconsistency and unpredictability. Different courts have very different
interpretations of the same contractual clause and can impose a wide array of rulings. Politics and
interests groups can impact on the outcome of rulings and debt restructurings, compromising
consistency and fairness.
The rulings have made future debt restructuring much more difficult as debtors are left with only
moral suasion and foreign relations as weapons to encourage creditor coordination. They have also
strengthened the hand of creditors even though their behaviour can be among the underlying causes
of debt crises.
The June 2014 IMF Policy Paper entitled "The Fund's lending framework and sovereign debt -
preliminary considerations" and its annexes (in a separate paper) reviewed the lessons of past debt
restructurings. However, when it comes to possible directions for reform, the proposals are to
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
3 de 4 25/06/2014 12:34 p.m.maintain a market-based approach (based on debt contracts) and debt reprofiling - extending debt
maturity - based on the IMF's judgement that an unsustainable debt situation exists. Debt
reprofiling has the potential to trigger credit default swaps and is viewed by some as a debt
restructuring. One wonders whether the IMF is best positioned to give timely and fair judgements
and how unsustainable debt could eventually be restructured when the world does not possess
sufficient tools to deal with the problems encountered so far. To rely on the market approach under
which different courts are to interpret clauses of the debt contracts as the United States Supreme
Court has done would lead to outcomes with "broad systemic implications", just as the IMF warned.
In this chaotic context, the formulation of global and harmonious rules and principles guiding
sovereign debt restructurings has become of paramount importance. This is why UNCTAD has been
a long-standing advocate of a sovereign debt workout mechanism and is currently working on a
project financed by the Government of Norway to further clarify how it could work in practice. The
list of general principles and issues identified thus far by a group of experts under the project
includes:
Standstill/stay of litigation
Debt thresholds and indicators
Transparency
Comprehensiveness and seniority (equity among creditors, collective action issues)
Legitimacy
Impartiality (institutional)
Institutional oversight and the relation between international and domestic levels.
1United States, Supreme Court of the United States, 2013, Syllabus, Republic of Argentina v. NML
Capital.
2Wall Street Journal, 2014, Argentina wants to continue paying its debts: but they won't let it, 21
June.
3A Phillips and J Johnston, 2013, Argentina vs. the vultures: What you need to know, 2 April, Center
for Economic and Policy Research.
4D Benson, 2012, Billionaire hedge funds snub 90% returns, Bloomberg News, 23 January.
5IMF, 2014, The Fund's lending framework and sovereign debt - preliminary considerations, IMF
Policy Paper, June.
6United States, Supreme Court of the United States, 2013, Syllabus, Republic of Argentina v. NML
Capital.
7United States, United States Court of Appeals for the Second Circuit, 2013, Brief for the United
States of America as amicus curiae.
8New York Times, 2014, Argentina's debt appeal is rejected by Supreme Court, 16 June.
News
There are no items to show.
unctad.org | Argentina's 'vulture fund' crisis threatens profound consequenc... http://unctad.org/en/pages/newsdetails.aspx?OriginalVersionID=783
4 de 4
