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229 substantive date for determination of COMI is "at the date of the opening of the foreign proceeding for which recognition is sought"). 2. Foreign Nonmain Proceeding: Establishment Unlike center of main interests, the Bankruptcy Code defines "establishment" as "any place of operations where the debtor carries out a non-transitory economic activity." 11 U.S.C. § 1502(2). Thus, in order for a foreign proceeding to be recognized as a nonmain proceeding, the debtor must have an office in the country in which the foreign proceeding is pending. It is not sufficient that the debtor only have assets in such country. C. Effects of Recognition of Foreign Proceeding 1. Relief in the Chapter 15 Proceeding The relief available in a Chapter 15 proceeding, while still broad, is narrower than in a plenary U.S. bankruptcy proceeding. This is especially true for a foreign nonmain proceeding, as certain types of relief are only available if the foreign proceeding is recognized as a foreign main proceeding. For example, although the automatic stay applies in a Chapter 15 proceeding, it only does so in a case based on a foreign main proceeding and only applies to property within the territorial jurisdiction of the U.S. 11 U.S.C. § 1520(a)(1); see In re JSC BTA Bank, 434 B.R. 334 (Bankr. S.D.N.Y. 2010) (holding that in rem jurisdiction of bankruptcy courts in the Chapter 15 context applies only to property of the debtor located "within the territorial jurisdiction of the United States," and not worldwide). Similarly, provisions regarding the use, sale or lease of the debtor's property also apply, but again only in a case based on a foreign main proceeding and only with respect to property within the territorial jurisdiction of the U.S. 11 U.S.C. § 1520(a)(2). The bankruptcy court also has the discretion to authorize types of relief to protect the debtor's assets, as well as the interests of creditors, whether or not the foreign proceeding is main or

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