Th. Day, SOLUTION FOR CONFLICT OF LAWS GOVERNING FRAUDULENT TRANSFERS - APPLY THE LAW THAT WAS ENACTED TO BENEFIT THE CREDITORS, The Business lawyer, 48(3), 1993, pp. 889-913
In this Article, Thomas H. Day analyzes the choice of law for fraudule
nt transfers in the context of the purposes of fraudulent transfer law
. He concludes that, because fraudulent transfer laws are enacted to p
rotect creditors from the disposition of a debtor's assets when the de
btor is insolvent or undercapitalized, the law of the location of the
creditors of the debtor should apply.