If there was an intention to defeat creditors, then it does not matter whether it was to defeat present or future creditors, see CIBC v. Boukalis 1987 CarswellBC 513 (B.C.C.A.). If an intent to defraud existed at the time of the conveyance, it does not matter that the person attacking it was not a creditor at the time, Iamgold v. Rosenfeld, [1998] O.J. 4690 (S.C.J.).
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