Compare and contrast the cramdown under Chapter 11 of the United States Bankruptcy Code and the cramdown under the new restructuring plan process pursuant to Part 26A of the UK’s Companies Act 2006.

Compare and contrast the cramdown under Chapter 11 of the United States Bankruptcy Code and the cramdown under the new restructuring plan process pursuant to Part 26A of the UK’s Companies Act 2006. Critically evaluate both cramdown regimes in respect of their relevance for modern restructuring practice.
(2750 words with footnotes Oscola reference style)