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The continuing drama relating to the demise of the Yukos Oil Co., Russia’s leading oil company, has generated two U.S. bankruptcy proceedings that have raised some of the most interesting cross-border insolvency issues in the last year. Both proceedings emanate from the pitched battle between Yukos’ management and equity investors, on the one hand — who assert that the Russian government is expropriating the company for its own benefit in violation of Russian and international law — and the Russian government and an interim insolvency receiver appointed by a Russian court (the Receiver), on the other hand — who assert that Yukos’ management caused the company to commit a tax fraud of approximately $27.5 billion that can only be resolved in a Russian court.

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