Can a voluntary settlement be challenged by subsequent creditors?

Mackay v. Douglas was a case of subsequent creditors attacking the settlement where there were no prior unsatisfied claims. The head-note in part says: “A voluntary settlement whereby the settlor takes the bulk of his property out of the reach of his creditors, shortly before engaging in trade of a hazardous character, may be set aside in a suit on behalf of creditors who become such after the settlement, though there are no creditors whose debts arose before the date of the settlement, and though when the settlement was made it was doubtful whether the arrangements under which the settlor was to engage in the business would take effect.”