Nevada Revised Statutes

Nev. Rev. Stat. § 112.180 (2026)

Transfer made or obligation incurred with intent to defraud or without receiving reasonably equivalent value; determination of intent

✓ current as of July 2026

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NRS 112.180 Transfer made or obligation incurred with intent to defraud or without receiving reasonably equivalent value; determination of intent.

1. 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 made the transfer or incurred the obligation:

(a) With actual intent to hinder, delay or defraud any creditor of the debtor; or

(b) Without receiving a reasonably equivalent value in exchange for the transfer or obligation, and the debtor:

(1) Was engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small in relation to the business or transaction; or

(2) Intended to incur, or believed or reasonably should have believed that the debtor would incur, debts beyond his or her ability to pay as they became due.

2. In determining actual intent under paragraph (a) of subsection 1, consideration may be given, among other factors, to whether:

(a) The transfer or obligation was to an insider;

(b) The debtor retained possession or control of the property transferred after the transfer;

(d) Before the transfer was made or obligation was incurred, the debtor had been sued or threatened with suit;

(e) The transfer was of substantially all the debtor’s assets;

(f) The debtor absconded;

(g) The debtor removed or concealed assets;

(h) The value of the consideration received by the debtor was reasonably equivalent to the value of the asset transferred or the amount of the obligation incurred;

(i) The debtor was insolvent or became insolvent shortly after the transfer was made or the obligation was incurred;

(j) The transfer occurred shortly before or shortly after a substantial debt was incurred; and

(k) The debtor transferred the essential assets of the business to a lienor who transferred the assets to an insider of the debtor.

(Added to NRS by 1987, 11)

Notes of Decisions

Cited in 47 cases (13 in the last 5 years), 1996–2026 · leading case: Herup v. First Boston Fin., LLC, 162 P.3d 870 (Nev. 2007).

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Herup v. First Boston Fin., LLC, 162 P.3d 870 (Nev. 2007). · cites it 11× “180(1)(a) and states, A transfer or obligation is not voidable under paragraph (a) of subsection 1 of NRS 112.180 against a person who took in good faith and for a reasonably equivalent value or against any subsequent transferee or obligee.”

Wells Fargo Bank, N.A. v. Radecki, 426 P.3d 593 (Nev. 2018). · cites it 4× “180(1)(b)(2) applicable, because there was no evidence that the homeowner "[i]ntended to incur, or believed or reasonably should have believed that [she] would incur, debts beyond .”

Sportsco Enter. v. Morris, 917 P.2d 934 (Nev. 1996). · cites it 2× “190(1), where a creditor's claim arose before a transfer made by a debtor, the transfer is fraudulent if the debtor did not receive "reasonably equivalent value in exchange" and was insolvent at the time of making the transfer or became so as a result of the transfer.”

In Re Stanton, 457 B.R. 80 (Bankr. D. Nev. 2011). · cites it 2× “2 (2006) (codified in Nevada at Nev. Rev.Stat. § 112.180(2)(a)-(k)). Comment 5 to that section explains this list: Subsection (b) is a nonexclusive cata-logue of factors appropriate for consideration by the court in determining whether the debtor had an actual intent to hinder,…”

In re EB Holdings II, Inc., 589 B.R. 704 (Bankr. D. Nev. 2017). · cites it 2× “The GoldenTree Plaintiffs allege that EBH transferred certain assets to defendants Meyers, Quexco, and RSR, with intent to hinder, delay, and defraud creditors, and that the alleged transfers are avoidable for actual fraud under the Nevada version of the Uniform Fraudulent…”

ShengdaTech Liquidating Trust v. Hansen (In re Shengdatech, Inc.), 519 B.R. 292 (D. Nev. 2014). · cites it 3× “*298 The claims alleged in the AC were: (1)— (3) professional negligence and malpractice, (4)-(5) breach of contract, and (6) fraudulent transfer under Nevada Revised Statutes (“NRS”) sections 112.180(l)(b) and 112.190(1). The Trust brought claims for professional negligence and…”

GW Grundbesitz AG v. Gunn (D. Nev. 2023). · cites it 32× “6 Nev. Rev. Stat. § 112.180 (1)(a). That statute lists various factors that courts may use to assess 7 whether actual intent is present.”

In re Tarkanian, 562 B.R. 424 (Bankr. D. Nev. 2014). “A judgment under NRS 112.180(l)(a) already had been entered in favor of the executing creditors, however, determining that the same debt- or had received a fraudulent transfer of funds owned by her stepson.”

Holland v. Anthony L. Barney, Ltd., 540 P.3d 1074 (Nev. 2023). “3d 550 , 554 (2023); see also NRS 112.180(1). When the creditor seeks a remedy for a fraudulent COURT OF APPEALS OF NEVA DA 21 II I Y47H c:o milat transfer under NRS 112.”

Bock, LLC v. Steelman (D. Nev. 2020). · cites it 11× “9 So Bock filed this 7 complaint on June 21, 2019, alleging that the Steelmans’ transfers to the various trusts are 8 fraudulent under NRS § 112.180(1) and NRS § 112.190(1). Bock also alleges the same claims 9 against Suzanne and Stephen (the Steelmans’ adult children), arguing…”

Deppoleto v. Takeover Indus. Inc. (D. Nev. 2025). · cites it 10× “Fraudulent Transfer 19 Plaintiff also seeks summary judgment on Count VII of the FAC for fraudulent transfer 20 against Takeover, Holley, McBride, Pavlik, and Zarro.”

Razaghi (D. Nev. 2025). · cites it 8× “Plaintiff specifically alleges the settlement violated NRS 112.180(1)(a)–(b) and NRS 13 112.190(1)–(2).”

Show all 47 citing cases →

— Nev. Rev. Stat. § 112.180(1) — 14 cases

Moh Mgmt., LLC v. Michelangelo Leasing, Inc. (Nev. 2019).

Holland v. Anthony L. Barney (Nev. 2023).

Holland v. Anthony L. Barney, Ltd. (Nev. 2023).

— Nev. Rev. Stat. § 112.180(1)(a) — 24 cases

Herup v. First Boston Fin., LLC, 162 P.3d 870 (Nev. 2007). “180(1)(a) and states, A transfer or obligation is not voidable under paragraph (a) of subsection 1 of NRS 112.180 against a person who took in good faith and for a reasonably equivalent value or against any subsequent transferee or obligee.”

In re EB Holdings II, Inc., 589 B.R. 704 (Bankr. D. Nev. 2017). “The GoldenTree Plaintiffs allege that EBH transferred certain assets to defendants Meyers, Quexco, and RSR, with intent to hinder, delay, and defraud creditors, and that the alleged transfers are avoidable for actual fraud under the Nevada version of the Uniform Fraudulent…”

Bock, LLC v. Steelman (D. Nev. 2020). “9 So Bock filed this 7 complaint on June 21, 2019, alleging that the Steelmans’ transfers to the various trusts are 8 fraudulent under NRS § 112.180(1) and NRS § 112.190(1). Bock also alleges the same claims 9 against Suzanne and Stephen (the Steelmans’ adult children), arguing…”

Razaghi (D. Nev. 2025). “Plaintiff specifically alleges the settlement violated NRS 112.180(1)(a)–(b) and NRS 13 112.190(1)–(2).”

GW Grundbesitz AG v. Gunn (D. Nev. 2023). “6 Nev. Rev. Stat. § 112.180 (1)(a). That statute lists various factors that courts may use to assess 7 whether actual intent is present.”

— Nev. Rev. Stat. § 112.180(1)(b) — 10 cases

Sportsco Enter. v. Morris, 917 P.2d 934 (Nev. 1996). “190(1), where a creditor's claim arose before a transfer made by a debtor, the transfer is fraudulent if the debtor did not receive "reasonably equivalent value in exchange" and was insolvent at the time of making the transfer or became so as a result of the transfer.”

Razaghi (D. Nev. 2025). “Plaintiff specifically alleges the settlement violated NRS 112.180(1)(a)–(b) and NRS 13 112.190(1)–(2).”

— Nev. Rev. Stat. § 112.180(1)(b)(1) — 5 cases

Wells Fargo Bank, N.A. v. Radecki, 426 P.3d 593 (Nev. 2018). “180(1)(b)(2) applicable, because there was no evidence that the homeowner "[i]ntended to incur, or believed or reasonably should have believed that [she] would incur, debts beyond .”

Wells Fargo Bank, N.A. Vs. Radecki, 2018 NV 74 (Nev. 2018).

Snow Covered Capital, LLC v. Fonfa (D. Nev. 2024).

United States v. Semenza II (D. Nev. 2025).

— Nev. Rev. Stat. § 112.180(1)(b)(2) — 4 cases

Wells Fargo Bank, N.A. Vs. Radecki, 2018 NV 74 (Nev. 2018).

Snow Covered Capital, LLC v. Fonfa (D. Nev. 2024).

— Nev. Rev. Stat. § 112.180(2) — 10 cases

Magliarditi Vs. Transfirst Grp., Inc (Nrap 5) (Nev. 2019).

Deppoleto v. Takeover Indus. Inc. (D. Nev. 2025). “Fraudulent Transfer 19 Plaintiff also seeks summary judgment on Count VII of the FAC for fraudulent transfer 20 against Takeover, Holley, McBride, Pavlik, and Zarro.”

Gingold v. Itronics, Inc. (D. Nev. 2025).

Razaghi (D. Nev. 2025). “Plaintiff specifically alleges the settlement violated NRS 112.180(1)(a)–(b) and NRS 13 112.190(1)–(2).”

— Nev. Rev. Stat. § 112.180(2)(a) — 4 cases

In Re Stanton, 457 B.R. 80 (Bankr. D. Nev. 2011). “2 (2006) (codified in Nevada at Nev. Rev.Stat. § 112.180(2)(a)-(k)). Comment 5 to that section explains this list: Subsection (b) is a nonexclusive cata-logue of factors appropriate for consideration by the court in determining whether the debtor had an actual intent to hinder,…”

Magliarditi Vs. Transfirst Grp., Inc (Nrap 5) (Nev. 2019).

GW Grundbesitz AG v. Gunn (D. Nev. 2023). “6 Nev. Rev. Stat. § 112.180 (1)(a). That statute lists various factors that courts may use to assess 7 whether actual intent is present.”

— Nev. Rev. Stat. § 112.180(2)(b) — 1 case

GW Grundbesitz AG v. Gunn (D. Nev. 2023). “6 Nev. Rev. Stat. § 112.180 (1)(a). That statute lists various factors that courts may use to assess 7 whether actual intent is present.”

— Nev. Rev. Stat. § 112.180(2)(c) — 1 case

GW Grundbesitz AG v. Gunn (D. Nev. 2023). “6 Nev. Rev. Stat. § 112.180 (1)(a). That statute lists various factors that courts may use to assess 7 whether actual intent is present.”

— Nev. Rev. Stat. § 112.180(2)(h) — 2 cases

GW Grundbesitz AG v. Gunn (D. Nev. 2023). “6 Nev. Rev. Stat. § 112.180 (1)(a). That statute lists various factors that courts may use to assess 7 whether actual intent is present.”

— Nev. Rev. Stat. § 112.180(d) — 1 case

— Nev. Rev. Stat. § 112.180(l)(a) — 1 case

— Nev. Rev. Stat. § 112.180(l)(b) — 2 cases

ShengdaTech Liquidating Trust v. Hansen (In re Shengdatech, Inc.), 519 B.R. 292 (D. Nev. 2014). “*298 The claims alleged in the AC were: (1)— (3) professional negligence and malpractice, (4)-(5) breach of contract, and (6) fraudulent transfer under Nevada Revised Statutes (“NRS”) sections 112.180(l)(b) and 112.190(1). The Trust brought claims for professional negligence and…”

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