|The new chapter 15 to the U.S. Bankruptcy Code does not give a clear choice of avoidance law rule, it merely gives "standing" to the foreign representative to use U.S. avoidance powers, The newly established Act on Rehabilitation and Bankruptcy of Debtor (so-called "the Consolidated Insolvency Act") of Korea also does not have an explicit choice of avoidance law rule, To solve the problems of the applicable law on the Consolidated Insolvency Act, it is necessary to review the U.S. courts decisions on international insolvency proceedings, which have the similar legislative system of Korea. Many §304 cases have followed the universality approach and have recognized and assisted foreign bankruptcy proceedings. One of these cases, Metzeler, has held that the avoiding powers to be applied in a §304 case are those powers vested in the foreign representative pursuant to the law of the jurisdiction in which the primary bankruptcy case occurs. The §303(b)(4) Axona case, have ordered the turnover of assets to foreign proceedings to be administered under U.S. avoidance law. Maxwell case, which commenced dual plenary bankruptcy proceedings in the U.S. and in the England, applies the law of the jurisdiction having the greatest interest in the avoidance action. Considering the fact that the debtor and most of its creditors were England, and the debt was incurred in England, British rather than US law should govern the avoidance action, As a result of the Fifth Circuit`s decision in Condor, assets transferred from the situs of a foreign main proceeding to the United States can be distributed to creditors under foreign avoidance law. Consequently, in the ancillary proceedings, the law that governs whether a transfer is fraudulent should be the law of the debtor`s home country at the time of the transfer. In the concurrent proceedings, courts will apply in principle local law and exceptionally foreign law.