Utah Code » Title 25, Chapter 6 — Uniform Voidable Transactions Act; part 25-6-3 — Transfers and Remedies
Utah Code

Utah Code § 25-6-305 (2026)

Claim for relief -- Time limits

✓ current as of May 2026
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A claim for relief regarding a transfer or obligation under this chapter is extinguished unless action is brought:

under Subsection 25-6-202(1)(a), no later than four years after the transfer was made or the obligation was incurred or, if later, no later than one year after the transfer or obligation was or could reasonably have been discovered by the claimant;
under Subsection 25-6-202(1)(b) or 25-6-203(1), no later than four years after the transfer was made or the obligation was incurred; or
under Subsection 25-6-203(2), no later than one year after the transfer was made.
Notes of Decisions
Cited in 12 cases (12 in the last 5 years), 2021–2025 · leading case: Hafen v. Percell (D. Utah 2022).
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Hafen v. Percell (D. Utah 2022). · cites it 8× “Whether the extinguishment provisions in Utah Code Ann. § 25-6-305 are statutes of limitation or statutes of repose.”
Hafen v. Larsen (D. Utah 2022). · cites it 8× “Whether the extinguishment provisions in Utah Code Ann. § 25-6-305 are statutes of limitation or statutes of repose.”
Hafen v. Muir (D. Utah 2022). · cites it 8× “Whether the extinguishment provisions in Utah Code Ann. § 25-6-305 are statutes of limitation or statutes of repose.”
Asphalt Trader Ltd. v. Beall (D. Utah 2021). · cites it 6× “They argue that the claims related to the Rim to River and Stone Canyon transfers are subject to the two-year statute of limitations for fraudulent transfers to asset protection trusts established by UTAH CODE § 25-6-502 and that the claim related to the Three Canyon transfer is…”
Hafen v. Taylor (D. Utah 2022). · cites it 5× “Does the one-year discovery period set forth in Utah Code Ann. § 25-6-305 (1) begin to run in a case involving a Ponzi scheme case when (i) an objectively reasonable creditor could have discovered the fraudulent transfer, or (ii) when the Ponzi schemer no longer controls the…”
Aerospace Eng'g & Support, Inc. (Bankr. D. Utah 2024). · cites it 2× “represents that the Transfers it seeks to avoid are prior to the four-year lookback period, documents it has submitted to the Court show otherwise.”
Hafen v. Larsen (D. Utah 2024). · cites it 2× “” Utah Code Ann. § 25-6-305 (1). The Beneficiary Defendants assert that no distributions made to them from the Larsen Trust occurred after April 2015,1 which was over four years before the Receiver filed this action on December 20, 2021, and that therefore the Receiver must rely…”
Hafen v. Guyon (D. Utah 2024). · cites it 2× “§§ 25-6-202 (1)(a), 25-6-305(1) or, if later, not later than one year after the transfer or obligation could have reasonably been discovered by the claimant, Utah Code Ann. § 25-6-305 (1). Under the UVTA, the statute of limitations is tolled for as long as an entity is…”
Newman Capital LLC v. Private Capital Grp., Inc. (S.D.N.Y. 2024). “” Utah Code § 25-6-305. A claim for intentional fraudulent transfer must be brought within the same amount of time, or “within one year after the transfer or obligation was or could reasonably have been discovered by the claimant.”
Newman Capital LLC v. Private Capital Grp., Inc. (S.D.N.Y. 2024). “” Utah Code § 25-6-305. A claim for intentional fraudulent transfer must be brought within the same amount of time, or “within one year after the transfer or obligation was or could reasonably have been discovered by the claimant.”
LuMee LLC v. Fernandez (Bankr. D. Utah 2023). “In analyzing the alleged fraudulent transfers, the Court will be using the statute of limitations of four years starting with the date of the petition (June 28, 2019) and going back four years to June 27, 2015, as allowed by state law (UCA § 25-6-305(1)-(2) and N.J. Rev. Stat. §…”
White v. Wardley (10th Cir. 2025). “” Utah Code Ann. § 25-6-305 (2) (West 2025).”
— Utah Code § 25-6-305(1) — 6 cases
Asphalt Trader Ltd. v. Beall (D. Utah 2021). “They argue that the claims related to the Rim to River and Stone Canyon transfers are subject to the two-year statute of limitations for fraudulent transfers to asset protection trusts established by UTAH CODE § 25-6-502 and that the claim related to the Three Canyon transfer is…”
LuMee LLC v. Fernandez (Bankr. D. Utah 2023). “In analyzing the alleged fraudulent transfers, the Court will be using the statute of limitations of four years starting with the date of the petition (June 28, 2019) and going back four years to June 27, 2015, as allowed by state law (UCA § 25-6-305(1)-(2) and N.J. Rev. Stat. §…”
Hafen v. Taylor (D. Utah 2022). “Does the one-year discovery period set forth in Utah Code Ann. § 25-6-305 (1) begin to run in a case involving a Ponzi scheme case when (i) an objectively reasonable creditor could have discovered the fraudulent transfer, or (ii) when the Ponzi schemer no longer controls the…”
Hafen v. Percell (D. Utah 2022). “Whether the extinguishment provisions in Utah Code Ann. § 25-6-305 are statutes of limitation or statutes of repose.”
Hafen v. Larsen (D. Utah 2022). “Whether the extinguishment provisions in Utah Code Ann. § 25-6-305 are statutes of limitation or statutes of repose.”
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