The Supreme Court’s recent decision in United States v. Miller (2025) re-affirmed the sovereign immunity of the federal government to most suits under 11 U.S.C. § 544(b). However, the decision did not otherwise affect the scope of permissible avoidance actions under § 544(b). Trustees, debtors-in-possession and parties eligible for derivative standing can avoid and recover for the benefit of the estate any pre-petition transfer that is voidable “under applicable law” by a creditor holding an allowable unsecured claim. Thus, the scope of § 544(b) depends on applicable non-bankruptcy law and the identities of the debtor’s actual unsecured creditors. The scope of § 544(b) is further limited by rules governing pre-petition charitable contributions (as defined elsewhere in the Bankruptcy Code and the Tax Code). Canvassing these various limitations, this presentation could be of interest to counsel prosecuting or defending against avoidance actions under § 544(b).