In an effort to hopefully prevent the spawn of even more threads on the subject, after reviewing those other threads quincy linked, I'll explain to you how the federal tax lien (FTL) works and how that relates to the situation you described.
The federal tax lien arises at the time of assessment of tax on all property and rights to property of the taxpayer if the tax is not paid. The IRS need not file anything; the FTL arises automatically by operation of law. The lien does not make the IRS an owner of any of the taxpayer's property. It does, however, give the IRS the right to take the property and sell it to apply to the tax liability that lien covers. While the IRS need not file anything to have that right against the taxpayer, it does need to file a notice of federal tax lien (NFTL) in order to enforce that lien against certain transferees of the taxpayer. The NFTL, once filed, puts the public on notice of the lien and thus buyers/transferees of the property would know that the lien will follow the property if they buy it/take it from the taxpayer. A buyer would typically want that lien off the property at the time of the sale. If the sale will fully pay the lien off, then that would solve the problem. If the sale wouldn't fully pay off the lien, then the buyer can apply for a certificate of discharge to remove that one property from the lien. To get the discharge, the IRS must be satisfied that it is getting its interest out of the property. That may or may not be the fair market value (FMV) of the property.
Ok, so as I understand it you asked about the following situation: Company A has a machine that is worth (FMV), let's say, $5,000. It transfers that machine to Company B for nothing. At the time of the transfer, there is a FTL against Company A for $100,000 and a NFTL giving the public notice of that lien was already recorded at the time of the transfer. Company A was also insolvent at the time of the transfer. Company B then seeks a certificate of discharge to get the machine out from under the FTL. The IRS agrees to take $5000 to issue the certificate of discharge, representing the FMV of the machine.
You want to know if Company B paying the IRS would affect a fraudulent conveyance claim by a creditor A. In this case it would. That's because Company A gets the benefit of the $5,000 that Company B paid to get the discharge — it reduces what Company A owes the IRS. And since the $5,000 that is applied to Company A's tax liability represents FMV, there is no fraudulent conveyance claim for the creditor to pursue. It is no different than had Company B paid the $5,000 to Company A for the machine and then Company A then paid the $5,000 to the IRS. The end result is the same in both situations. And the latter clearly does not give rise to a fraudulent conveyance situation.
Now let's suppose the same facts as before but instead of paying the IRS $5,000 for the certificate of discharge, Company B only pays $500. (The IRS wouldn't give a certificate of discharge for that amount in these facts, but for purposes of illustration let's say it does anyway.) Now Company A is only getting $500 credit towards the taxes for the machine it transferred. So in this situation Company A has only gotten $500 for a machine it transferred to Company worth $5,000 at time it was insolvent. A creditor of A might well have a fraudulent conveyance claim to make there since the end result is that the machine was transferred to Company B for significantly less than FMV. But would it be worth it for the creditor to do that? The result of voiding the transfer under the fraudulent conveyance statute is that the asset returns to Company A. But Company A has a FTL against it for $99,500 (after credit for the $500 Company B paid for the discharge). When the asset is returned to Company A, the FTL reattaches to the asset. If the creditor does not have lien priority over the IRS then there is no value for the creditor in the machine — the IRS lien would have first claim to it leaving nothing for the creditor. So the creditor would be wasting its time and money going after it.
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