derivative interest in the property is insufficient, citing Citik Ka Wah Bank, Ltd. v. Wong (In re Wong), 291 B.R. 266, 282 (Bankr.S.D.N.Y.2003). However, In re Wong involved a debtor transferring assets of a non-bankrupt corporation of which the debtor was a principal, thus distinguishing corporate assets from the debtor-principal’s individual assets. Id. In this case, Palermo admits that the Palermo entities contain only Palermo’s money. The shell entities are all the equivalent of Palermo’s bank account, and the money owed to him by agreement with 455 CPW, LLC is his direct interest. Third, Palermo argues that the transfer itself was not performed by the debtor, citing Nate B. & Francis Spingold Foundation, Inc. v. Halperin (In re Halperin), 215 B.R. 321, 332-33 (Bankr.E.D.N.Y.1997) (<HOLDING>). However, since the fee amendment schemes were
holding that the principal of a corporate debtor does not become a transferee by the mere act of causing the debtor to make a fraudulent transfer holding that a debtor need not have received a benefit from the fraudulent activity in order for  523a2a to prevent a discharge holding that where the debtor did not act but merely had knowledge of and benefit from the fraudulent transfer he was not considered to have performed it holding where plaintiffs transfer between employee benefit plans generated tax liability that fact that plaintiffs may have performed the transfer pursuant to advice from defendants does not convert plaintiffs tax liability into consequential damages recognizing potential for fraudulent transfer in foreclosure context if debtor enjoyed significant equity in property but received little or no value from the transfer