Foreign investors who are concerned about the extraterritorial application of U.S. bankruptcy law can draw some comfort from a recent decision in the liquidation case of Bernard L. Madoff Investment Securities ("BLMIS"). On July 6, 2014, United States District Court Judge Jed S. Rakoff ruled that the BLMIS Trustee could not use the Bankruptcy Code's avoidance provisions to recover transfers made to foreign investors that had invested in foreign feeder funds, such as the Fairfield Funds. 2014-07-06_BLMIS Decision
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