What is the definition of a transfer of assets between a husband and wife?

Plaintiffs counsel attempted to argue that this was not a transfer as contemplated under s. 160 of the Act. I am satisfied that Mr. Justice Thurlow, in the Dunkelman v. M.N.R. (1959), 59 D.T.C. 1242, put the definition to rest when he wrote at p. 1244: "The word 'transfer' is not a term of art and has not a technical meaning. It is not necessary to a transfer of property from a husband to his wife that it should be made in any particular form or that it should be made directly. All that is required is that the husband should so deal with the property as to divest himself of it and vest it in his wife, that is to say, pass the property from himself to her. The means by which he accomplishes this result, whether direct or circuitous, may properly be called a transfer." I accept this definition and I conclude that there was in fact a transfer of assets, but the matter does not end here.