Idaho Code

Idaho Code § 55-910 (2026)

Uniform voidable transactions act — Definitions.

✓ current as of May 2026

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Uniform voidable transactions act — Definitions.

As used in this act:

(1) "Affiliate" means:

(a) A person that directly or indirectly owns, controls, or holds with power to vote, twenty percent (20%) or more of the outstanding voting securities of the debtor, other than a person that holds the securities:

1. as a fiduciary or agent without sole discretionary power to vote the securities; or

2. solely to secure a debt, if the person has not in fact exercised the power to vote;

(b) A corporation twenty percent (20%) or more of whose outstanding voting securities are directly or indirectly owned, controlled, or held with power to vote, by the debtor or a person that directly or indirectly owns, controls, or holds with power to vote, twenty percent (20%) or more of the outstanding voting securities of the debtor, other than a person that holds the securities:

1. as a fiduciary or agent without sole discretionary power to vote the securities; or

2. solely to secure a debt, if the person has not in fact exercised the power to vote;

(c) A person whose business is operated by the debtor under a lease or other agreement, or a person substantially all of whose assets are controlled by the debtor; or

(d) A person that operates the debtor’s business under a lease or other agreement or controls substantially all of the debtor’s assets.

(2) "Asset" means property of a debtor, but the term does not include:

(a) Property to the extent it is encumbered by a valid lien;

(b) Property to the extent it is generally exempt under nonbankruptcy law.

(3) "Claim" means a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured, or unsecured.

(4) "Creditor" means a person that has a claim.

(5) "Debt" means liability on a claim.

(6) "Debtor" means a person that is liable on a claim.

(7) "Electronic" means relating to technology having electrical, digital, magnetic, wireless, optical, electromagnetic or similar capabilities.

(8) "Insider" includes:

(a) If the debtor is an individual:

1. a relative of the debtor or of a general partner of the debtor;

2. a partnership in which the debtor is a general partner;

3. a general partner in a partnership described in subsection (7)(a)2. of this section; or

4. a corporation of which the debtor is a director, officer, or person in control;

(b) If the debtor is a corporation:

1. a director of the debtor;

2. an officer of the debtor;

3. a person in control of the debtor;

4. a partnership in which the debtor is a general partner;

5. a general partner in a partnership described in subsection (7)(b)4. of this section; or

6. a relative of a general partner, director, officer, or person in control of the debtor;

1. a general partner in the debtor;

2. a relative of a general partner in, or a general partner of, or a person in control of the debtor;

3. another partnership in which the debtor is a general partner;

4. a general partner in a partnership described in subsection (7)(c)3. of this section; or

5. a person in control of the debtor;

(d) An affiliate, or an insider of an affiliate as if the affiliate were the debtor; and

(e) A managing agent of the debtor.

(9) "Lien" means a charge against or an interest in property to secure payment of a debt or performance of an obligation, and includes a security interest created by agreement, a judicial lien obtained by legal or equitable process or proceedings, a common-law lien, or a statutory lien.

(10) "Organization" means a person other than an individual.

(11) "Person" means an individual, estate, business or nonprofit entity, public corporation, government or governmental subdivision, agency or instrumentality, or any other legal entity.

(12) "Property" means anything that may be the subject of ownership.

(13) "Record" means information that is inscribed on a tangible medium or that is stored in an electronic or other medium and is retrievable in perceivable form.

(14) "Relative" means an individual related by consanguinity within the third degree as determined by the common law, a spouse, or an individual related to a spouse within the third degree as so determined, and includes an individual in an adoptive relationship within the third degree.

(15) "Sign" means, with present intent to authenticate or adopt a record:

(a) To execute or adopt a tangible symbol; or

(b) To attach to or logically associate with the record an electronic symbol, sound or process.

(16) "Transfer" means every mode, direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease, license and creation of a lien or other encumbrance.

(17) "Valid lien" means a lien that is effective against the holder of a judicial lien subsequently obtained by legal or equitable process or proceedings.

Notes of Decisions

Cited in 23 cases (7 in the last 5 years), 1991–2025 · leading case: Clarke v. Latimer, 437 P.3d 1 (Idaho 2018).

Sort: Relevance Newest Treatment

Clarke v. Latimer, 437 P.3d 1 (Idaho 2018). · cites it 8× “After obtaining a judgment against Latimer, the Clarkes filed a separate action against his wife, Holly Latimer, alleging that the Latimers engaged in transfers of funds that violated the Uniform Fraudulent Transfer Act, *4 I.C. §§ 55-910 to 55-921. The district court found in…”

Hillen v. City of Many Trees (In re CVAH, Inc.), 570 B.R. 816 (Bankr. D. Idaho 2017). · cites it 4× “Both the FDCPA and Idaho UFTA define a “claim” as “a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured, or unsecured.”

Post v. Idaho Farmway, Inc., 20 P.3d 11 (Idaho 2001). · cites it 4× “” Idaho Code § 55-910 (12) defines transfer as “every mode, direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease, and creation of a lien or other…”

Dunham v. Dunham, 910 P.2d 169 (Idaho Ct. App. 1994). · cites it 16× “" I.C. § 55-910(10). The evidence presented at trial indicates that Roger gifted most, if not all, of his inherited money to Belinda in August of 1989.”

High Valley Concrete, LLC v. Sargent, 234 P.3d 747 (Idaho 2010). · cites it 2× “” I.C. § 55-910(7)(e). Here, there was no evidence that HKHC was acting as an agent of Sargent.”

Rainsdon v. Garcia (In re Garcia), 465 B.R. 181 (Bankr. D. Idaho 2011). · cites it 2× “Plaintiff alleges a fraudulent transfer under Idaho Code § 55-910 , et seq. However, that section merely includes the definitions governing Idaho's fraudulent transfer statutes.”

Wilder v. Miller, 17 P.3d 883 (Idaho Ct. App. 2000). · cites it 4× “Idaho Code § 55-910 (3) defines “claim” as "a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured, or unsecured.” 3 . We do note that the Millers argue…”

Zazzali Ex Rel. DBSI Est. Litig. Trust v. Swenson (In Re DBSI, Inc.), 463 B.R. 709 (Bankr. D. Del. 2012). “The Third Count of the Complaint pleads actual fraud under §§ 55-913(a) ("A transfer made or obligation incurred by a debtor is fraudulent as to a creditor, whether the creditor’s claim arose before or after the transfer was made or the obligation was incurred, if the debtor…”

DesFosses v. DesFosses, 836 P.2d 1095 (Idaho Ct. App. 1992). · cites it 2× “1 Annie filed this separate action in 1988 under the Uniform Fraudulent Transfer Act, I.C. § 55-910 to -921, to establish the ownership of property which could be used to satisfy the divorce judgment’s monetary awards to Annie.”

Zazzali v. United States (In Re DBSI, Inc.), 869 F.3d 1004 (9th Cir. 2017). “§§ 101 (10), (13), (15), (41); Idaho Code §§ 55-910 (4), (9). In turn, both Section 544(b)(1) and Idaho’s UFTA provide a substantive cause of action against the government—i.”

Dyer v. Eckols, 808 S.W.2d 531 (Tex. App. 1991). “§§ 651C-1 to 651C-10 (1988); Idaho Code §§ 55-910 to 55-921 (1988); Ill.”

Alcan Bldg. Prods. v. Peoples, 859 P.2d 374 (Idaho Ct. App. 1993). · cites it 2× “An “insider” is defined in I.C. § 55-910(7) to include a director of the debtor, an officer of the debtor, and a person in control of the debtor, where the alleged debtor is a corporation.”

Show all 23 citing cases →

— Idaho Code § 55-910(1) — 2 cases

Powell v. Crypto Traders Mgmt., LLC (D. Idaho 2021).

— Idaho Code § 55-910(10) — 1 case

Dunham v. Dunham, 910 P.2d 169 (Idaho Ct. App. 1994). “" I.C. § 55-910(10). The evidence presented at trial indicates that Roger gifted most, if not all, of his inherited money to Belinda in August of 1989.”

— Idaho Code § 55-910(12) — 2 cases

Post v. Idaho Farmway, Inc., 20 P.3d 11 (Idaho 2001). “” Idaho Code § 55-910 (12) defines transfer as “every mode, direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease, and creation of a lien or other…”

— Idaho Code § 55-910(16) — 1 case

Geile v. Wickersham (Bankr. D. Idaho 2023).

— Idaho Code § 55-910(2) — 2 cases

Geile v. Wickersham (Bankr. D. Idaho 2023).

— Idaho Code § 55-910(2)(b) — 1 case

Clarke v. Latimer, 437 P.3d 1 (Idaho 2018). “After obtaining a judgment against Latimer, the Clarkes filed a separate action against his wife, Holly Latimer, alleging that the Latimers engaged in transfers of funds that violated the Uniform Fraudulent Transfer Act, *4 I.C. §§ 55-910 to 55-921. The district court found in…”

— Idaho Code § 55-910(3) — 5 cases

Powell v. Crypto Traders Mgmt., LLC (D. Idaho 2021).

The Gov't of the Lao People's Democratic Repub. v. Baldwin (D. Idaho 2021).

— Idaho Code § 55-910(6) — 1 case

Powell v. Crypto Traders Mgmt., LLC (D. Idaho 2021).

— Idaho Code § 55-910(7) — 1 case

Alcan Bldg. Prods. v. Peoples, 859 P.2d 374 (Idaho Ct. App. 1993). “An “insider” is defined in I.C. § 55-910(7) to include a director of the debtor, an officer of the debtor, and a person in control of the debtor, where the alleged debtor is a corporation.”

— Idaho Code § 55-910(7)(a) — 1 case

Wilder v. Miller, 17 P.3d 883 (Idaho Ct. App. 2000). “Idaho Code § 55-910 (3) defines “claim” as "a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured, or unsecured.” 3 . We do note that the Millers argue…”

— Idaho Code § 55-910(7)(e) — 1 case

High Valley Concrete, LLC v. Sargent, 234 P.3d 747 (Idaho 2010). “” I.C. § 55-910(7)(e). Here, there was no evidence that HKHC was acting as an agent of Sargent.”

— Idaho Code § 55-910(8) — 1 case

Powell v. Crypto Traders Mgmt., LLC (D. Idaho 2021).

— Idaho Code § 55-910(8)(a) — 1 case

Geile v. Wickersham (Bankr. D. Idaho 2023).

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