U.S. Bankruptcy and appellate courts have long wrangled over whether the provisions of the Bankruptcy Code apply extraterritorially to permit, for example, enforcement of the automatic stay to creditor collection efforts against a debtor or property of its bankruptcy estate outside of the United States, or avoidance and recovery of voidable pre-bankruptcy transfers from non-U.S. creditors by a bankruptcy trustee or chapter 11 debtor-in-possession (“DIP”).
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