What is the most persuasive factor leading to a finding of fraud in a case of close relationship between the debtor and the transferee?

In Krumm Romaine J. found that the most persuasive factor leading to a finding of fraud was the relationship between the debtor and the transferee. She applied the evidentiary rule governing cases of close relationship between a transferor and a transferee set out by Davies J. in Koop v. Smith (1915), 1915 CanLII 26 (SCC), 8 W.W.R. 1203 (S.C. C.) (at page 1205) as follows: I think the true rule is that suspicious circumstances coupled with a relationship make a case of res ipsa loquitur which the tribunal of fact may and will generally treat as a sufficient prima facie case, but that it is not strictly in law bound to do so; and that the question of the necessity of corroboration is strictly a question of fact.