The Court of Appeals upheld an order letting a wife transfer her share of a business to the husband to satisfy a monetary award in Linton v. Linton, 63 Va. App. 495, 500, 759 S.E.2d 14, 16 (2014). The Court said that while Code § 20-107.3(C) says
C. Except as provided in subsection G, the court shall have no authority to order the division or transfer of separate property or marital property, or separate or marital debt, which is not jointly owned or owed. ...
This transfer was a court-approved means of satisfying a monetary award made under Code § 20-107.3(D), which says
D. In addition ... the court has the power to grant a monetary award, payable either in a lump sum or over a period of time in fixed amounts, to either party. The party against whom a monetary award is made may satisfy the award, in whole or in part, by conveyance of property, subject to the approval of the court. ...
The Court explains:
Code § 20-107.3(C) applies only to the transfer or division of property without any reference to the satisfaction of a monetary award. A transfer or division of property to satisfy a monetary award would be controlled by Code § 20-107.3(D). These two statutes address completely different situations in the equitable distribution statutory scheme.