Category: Passing of Accounts

31 May

Estate Trustee Duties 101

Hull & Hull LLP Executors and Trustees, In the News, Litigation, Passing of Accounts Tags: , , , , , 0 Comments

The duties owing by an Estate Trustee are plentiful and onerous.  It is important for an Estate Trustee, as soon as stepping into office, to understand their obligations and prioritize the steps to be completed.

There have been concerns rising out of Australia where firms have been billing clients, now deceased, for services that they are no longer providing.  The Australian Broadcasting Corporation, as well as Bloomberg, have reported that many financial institutions have been billing clients notwithstanding their own internal documents confirm that services are not being provided and that their client is dead.  In some instances, clients who had passed away ten years prior, were still being charged.

This serves as a helpful reminder that Estate Trustees should immediately take steps to cancel the deceased’s numerous accounts/subscriptions that are no longer needed and that may automatically renew.  These include, telephone, internet, magazine/newspaper, and the gym.  And of course, the bank!  An estate account should also be opened in order to deposit income and to pay any necessary expenses that may arise.

An Estate Trustee does not want to deliver an accounting, replete with payments for services that are no longer necessary.  This would certainly impact a claim for compensation.

Solicitors assisting an Estate Trustee with the administration of an estate often provide checklists to ensure such obligations are met.

Noah Weisberg

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24 Apr

Re Wall Estate, Part 2: Passings of Account, Laches and Acquiescence

Umair Estate & Trust, Litigation, Passing of Accounts, Power of Attorney, Trustees, Wills 0 Comments

In my last blog post, I wrote about Justice Mulligan’s recent decision in Re Shaw Estate, 2018 ONSC 1735, and the question of whether a notice of objection filed in a passing of accounts by an Estate Trustee is a “claim” pursuant to the Limitations Act, 2002.

Upon concluding that the notice of objection was not a “claim” – and thus was not statute-barred – on the facts, Justice Mulligan went on to consider the application of the defences of laches and acquiescence.

The Defences of Laches and Acquiescence

The Court turned to the definition of “laches” in Black’s Law Dictionary, which defines it to be “[u]nreasonable delay in pursuing a right or claim – almost always an equitable one – in a way that prejudices the party against whom relief is sought.” The Court also looked to the decision of Lindsay Petroleum Co. v Hurd, [18740 JCJ No 2, which held that the length of the delay and the nature of the acts done during the interval are two important circumstances when considering the question of laches.

Justice Mulligan also cited to the Supreme Court of Canada’s decision in MK v HM, [1992] SCJ No 85, which considered the basic principles surrounding laches and acquiescence:

Acquiescence is a fluid term susceptible to various meanings depending upon the context in which it is used…the first being a synonym for estoppel, wherein the plaintiff stands by and watches the deprivation of her rights and yet does nothing.  This has been referred to as the primary meaning of acquiescence.  Its secondary sense is as an element of laches – after the deprivation of her rights and in the full knowledge of their existence, the plaintiff delays.  This leads to an inference that her rights have been waived.  This, of course, is the meaning of acquiescence relevant to this appeal.  The final stage is a confusing one, as it is sometimes associated with the second branch of the laches rule in the context of an alteration of the defendant’s position in reliance on the plaintiff’s inaction.

Application in Re Shaw Estate

Turning to the facts in Re Shaw Estate, there was evidence that there were meetings between the Estate Trustee and the testator’s children but a dispute about what happened at those meetings. The Estate Trustee asserted that copies of his accounts were presented to the testator’s daughter at the meetings, and that she (along with her brother before he passed away) approved the Estate Trustee’s accounts and claim for compensation. There was evidence that the beneficiaries had initialed the statements presented at these meetings.

In her affidavit evidence filed in response, the testator’s daughter denied the Estate Trustee’s characterization of these meetings. It was her evidence that the accounts were presented to her over lunch, and that she did not receive fulsome information regarding investments or bank account statements.

Although there were material facts in dispute as between the Estate Trustee and the objecting beneficiary, it was undisputed that the testator’s daughter had not signed a release and that the Estate Trustee had not passed his accounts. It was also undisputed that copies of the annual accounts were not sent to the testator’s daughter in advance of the meetings, and that no arrangements were made for her to obtain independent legal advice.

After reviewing the factual evidence, Justice Mulligan concluded that the doctrine of laches did not apply. Justice Mulligan also held that the annual meetings and the initialing of the statements did not lead to a finding of acquiescence in the present case.

Lessons to be Learned from Wall Estate

For estate trustees and fiduciaries seeking to have their accounts and their claim for compensation approved without the necessity of a formal passing of accounts, the Court’s decision in Re Wall Estate is an important reminder regarding the best practices to be followed.

Generally speaking, it is prudent for a fiduciary in such a situation to provide the beneficiaries with a copy of his or her accounts and carefully document any discussions with the beneficiaries regarding the accounts. It is also prudent for a fiduciary to recommend that the beneficiaries obtain independent legal advice regarding the accounts and obtain a form of release for the accounting period.

Thank you for reading,

Umair Abdul Qadir

 

23 Apr

Re Wall Estate: Can A Notice of Objection to Accounts Be Statute-Barred?

Umair Estate & Trust, Executors and Trustees, Litigation, Passing of Accounts, Power of Attorney, Public Policy, Trustees, Wills 0 Comments

Is a notice of objection to accounts, filed by a responding party in the context of an Application to pass accounts by an estate trustee, a “claim” within the meaning of the Limitations Act, 2002?

The answer to this question could have significant consequences for individuals with a financial interest: the general two-year limitation period under the Limitations Act, 2002 may apply to a “claim,” and objections that fall outside the period may be statute-barred.

The Honourable Justice Mulligan of the Ontario Superior Court of Justice addressed this issue in Re Wall Estate, 2018 ONSC 1735.

A Recent History of Limitation Periods and Passing of Accounts

In Armitage v The Salvation Army, 2016 ONCA 871, the Court of Appeal held that a passing of accounts by an attorney for property under the Substitute Decisions Act was not subject to the general two-year limitation period under the Limitations Act, 2002.

Writing for a unanimous court, Justice Hourigan noted that there was historically no statutory limitation period for the passing of accounts. Justice Hourigan concluded that the enactment of the Limitations Act, 2002 did not establish a two-year limitation period for passing of accounts, because a passing did not fit the definition of a “claim” as defined by the Act. Given the Court’s conclusion, the equitable doctrine of laches and acquiescence were the only defences available.

However, in a footnote to the judgment, Justice Hourigan specifically noted that the judgment did not mean that the Act categorically has no applicability to passings. In particular, Justice Hourgan left open the possibility that the filing of a notice of objection in a passing of accounts is a “claim” within the meaning of the Act.

Wall Estate: Is An Objection A Claim?

In Re Wall Estate, the testator died in 2005. The Estate Trustee had annual meetings with the testator’s two children, who were the beneficiaries of testamentary trusts. However, the beneficiaries did not sign releases and the Estate Trustee did not pass his accounts.

The testator’s daughter subsequently compelled a passing of accounts from the Estate Trustee in 2014, and the Estate Trustee was removed in 2016. The testator’s daughter filed an objection to the Estate Trustee’s accounts in June 2015.

The Estate Trustee brought a motion to strike the objections to his accounts, and argued that he was not required to address objections to his accounts for the period prior to December 31, 2012 due to the Limitations Act, 2002, laches or acquiescence.

After discussing Justice Hourigan’s decision in Armitage, Justice Mulligan concluded that the notice of objection filed by the testator’s daughter was not statute-barred:

In my view, if the passing of accounts does not constitute a claim, I am not satisfied that a Notice of Objection is a claim.  In filing a Notice of Objection, the beneficiary is seeking answers to questions about steps taken by the estate trustee during the currency of an administration of an estate.  Answers to those questions may assist the beneficiary in consenting to the passing of accounts without the necessity of a formal hearing.  An absence of consent will require a formal hearing.  A formal hearing will assist the court in determining if the fees sought and investment steps taken are appropriate under all the circumstances.

The objections taken at their highest may result in a reduction or loss of compensation for the estate trustee or other remedies.  In this case, if the objections are successful to any extent, no additional funds would be payable immediately to Elizabeth as beneficiary of the discretionary trust.  The corpus of the estate would be enlarged, increasing the funds available for the discretionary trust, and ultimately, could increase the amount available to be paid to Elizabeth, but only if she survives to age 60.  On the facts here, I am not satisfied that the Notice of Objection rises to the level of a “claim” as contemplated by the Limitations Act, 2002.

What’s On the Other Side of the Wall Decision?

Given that the question was left open in Armitage, it remains to be seen if Re Wall Estate or another case that raises this limitations defence will be appealed to a higher court.

In addition, Justice Mulligan noted that the objections did not rise to the level of a claim “on the facts here.” Thus, Re Wall Estate leaves open the possibility that the Court may reach the opposite conclusion after making a fact-specific enquiry.

In tomorrow’s blog post, I will discuss the issues of laches and acquiescence, which were also pleaded as defences in Re Wall Estate.

Thank you for reading,

Umair Abdul Qadir

12 Mar

Should I Bring a Motion in the Estates Court Without Notice?

Hull & Hull LLP Estate & Trust, General Interest, Litigation, Passing of Accounts Tags: , , , , , , , , , , 0 Comments

When is it appropriate to bring a motion in the Estates Court without notice?   The answer requires consideration of both the statute and common law.

The starting point is Rule 74.15(1) of the Rules of Civil Procedure.  Here, a person who has a financial interest in an estate is permitted to seek an order for assistance.  Some of the more ‘popular’ orders for assistance include: requiring a person to accept/refuse an appointment as estate trustee; requiring an estate trustee to file with the court a statement of the nature and value of the estate assets at the date of death; and, requiring an estate trustee to pass accounts.

Subject to narrow exceptions, Rule 74.15(2) allows these motion to be made without notice (in latin, ex parte).

Notwithstanding this, the Court has not necessarily embraced ex-parte orders with open arms.

For instance, Corbett J. in Robert Half Canada Inc. v. Jeewan found that, before ordering an ex parte injunction, a party needed to demonstrate some element of ‘extraordinary urgency’.

Moreover, and specifically in relation to estates orders for assistance, Justice DM Brown in Ignagni Estate (Re), noted that orders for assistance are not mere administrative devices, and that the consequences of failing to abide by such an order is significant.  He went on to say that, “[m]embers of the Estates Bar may regard the requirement to give notice of a motion for an order for assistance unless “extraordinary urgency” exists as imposing undue costs on the administration of the estate.  Against that must be weighed the fundamental principle that a court should not issue an order against a person without affording that person an opportunity to explain the other side of the story.  Many estate disputes arise in the context of strained family relationships, or out-and-out family battles.  Courts should exercise great caution before granting an order that imposes obligations on one side in a family dispute.  Unless some extraordinary urgency exists, prudence and the principles of natural justice require a moving party to give notice of the order requested so that the respondent enjoys the opportunity of placing the rest of the story before the court.”

Given this, although permissible, parties who intend to seek orders for assistance without notice, must ensure there is ‘extraordinary urgency’ in doing so.

Noah Weisberg

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22 Feb

Was there a breach of duty? The Q&A from the New SCC Decision

Doreen So Estate & Trust, Executors and Trustees, General Interest, In the News, Passing of Accounts, Trustees Tags: , , , , , , 0 Comments

The facts in the new Supreme Court of Canada decision on trustee duties were previously set out in last Tuesday’s edition of this blog.

Valard Construction Ltd. v. Bird Construction Co. arose from a commercial matter in which Valard was a subcontractor in a construction oilsands project where Bird was the general contractor.  Bird was the trustee of a labour and material payment bond that could have been available for Valard’s claim for unpaid invoices if notice of claim was given to the surety within a fixed time limit.  Valard claimed against Bird when Bird failed to disclose the existence of the bond to Valard within the relevant time period.

Justice Brown, for the majority, found that Bird had a fiduciary duty to disclose the bond to Valard even though Valard did not explicitly ask about the existence of the bond until it was too late.  In order to determine whether a breach of trust occurred, Justice Brown went on to consider what was required of Bird in order to discharge its duties to Valard because “the question is not what Bird could have done in this case, but what Bird should reasonably have done in the circumstances of this case to notify beneficiaries such as Valard of the existence of the bond” (paragraph 29).  In concluding that the duty was breached in this instance, paragraph 26 is particularly instructive for the analysis:

Like all duties imposed upon trustees, the standard to be met in respect of this particular duty is not perfection, but rather that of honesty, and reasonable skill and prudence.[31] And the specific demands of that standard, so far as they arise from the duty to disclose the existence of a trust, are informed by the facts and circumstances of which the trustee ought reasonably to have known at the material time.[32] In considering what was required in a given case, therefore, a reviewing court should be careful not to ask, in hindsight, what could ideally have been done to inform potential beneficiaries of the trust.  Rather, the proper inquiry is into what steps, in the particular circumstances of the case — including the trust terms, the identity of the trustee and of the beneficiaries, the size of the class of potential beneficiaries and pertinent industrial practices — an honest and reasonably skillful and prudent trustee would have taken in order to notify potential beneficiaries of the existence of the trust. But, where a trustee can reasonably assume that the beneficiaries knew of the trust’s existence, or where practical exigencies would make notification entirely impractical,[33] few, if any, steps may be required by a trustee.

In this case, Justice Brown found that Bird could have reasonably discharged its duties by posting notice of the bond on its information board and that some method of notice was required of the company to notify beneficiaries like Valard with a caveat.  The caveat being that, in some circumstances, nothing could be required to discharge this duty where industry practice and knowledge would render notice unnecessary.

Interestingly, what was or was not industry practice in this case was the question that divided the Court.  For Justice Karakatsanis‘ dissenting opinion, she would have dismissed the appeal because Bird was not under an obligation to inform Valard beyond responding accurately when asked because this type of bond was common in this industry in her view.

Thanks for reading!

Doreen So

20 Feb

New SCC Decision on Duty to Disclose Trust to Beneficiaries

Doreen So Continuing Legal Education, Estate & Trust, Executors and Trustees, Passing of Accounts, Trustees, Uncategorized Tags: , , , , , 0 Comments

The Supreme Court of Canada released a decision last Thursday that is a must read for estates and trusts practitioners.  Interestingly enough, Valard Construction Ltd. v. Bird Construction Co., 2018 SCC 8, arose from a commercial matter.

Bird was a general contractor for a construction project.  When Bird subcontracted with Langford, Langford was required to obtain a labour and material payment bond which named Bird as trustee of the bond.  If Langford was delinquent in paying its contractors, the bond would permit the contractor to sue and recover from Langford’s surety on the condition that notice of the claim must be made within 120 days of the last date in which work was provided to Langford.  Langford became insolvent and some of Valard’s invoices went unpaid.  Unfortunately, Valard was not notified of the existence of the bond and did not inquire about whether there was a bond in place until after the 120 day notice period.  The surety denied Valard’s claim and Valard sued Bird for breach of trust.  This matter was dismissed at first instance by the Alberta Queen’s Bench, dismissed again by the Alberta Court of Appeal, and finally reversed by the Supreme Court of Canada (with a dissent from Justice Karakatsanis).

Justice Brown for the majority (per McLachlin C.J., as she then was, Abella, Moldaver and Rowe J.J.) found that Bird had a fiduciary duty to disclose the terms of the trust, i.e. the bond, to Valard notwithstanding the fact that the express terms of the bond did not stipulate this requirement.  Justice Brown was clear that “While the ‘main source’ of a trustee’s duties is the trust instrument, the ‘general law’ which sets out a trustee’s duties, rights and obligations continues to govern where the trust instrument is silent” (para.15).  Justice Brown then went on to say that a beneficiary’s right to enforce the terms of the trust is precisely what keeps the trustee from holding the “beneficial as well as legal ownership of the trust property” (para. 18).  Otherwise, no one would have an interest in giving effect to the trust.

With this logic in mind, Justice Brown developed the following framework at paragraph 19,

“In general, wherever “it could be said to be to the unreasonable disadvantage of the beneficiary not to be informed” of the trust’s existence,[17] the trustee’s fiduciary duty includes an obligation to disclose the existence of the trust. Whether a particular disadvantage is unreasonable must be considered in light of the nature and terms of the trust and the social or business environment in which it operates,[18] and in light of the beneficiary’s entitlement thereunder. For example, where the enforcement of the trust requires that the beneficiary receive notice of the trust’s existence, and the beneficiary would not otherwise have such knowledge, a duty to disclose will arise.[19] On the other hand, “where the interest of the beneficiary is remote in the sense that vesting is most unlikely, or the opportunity for the power or discretion to be exercised is equally unlikely”,[20] it would be rare to find that the beneficiary could be said to suffer unreasonable disadvantage if uninformed of the trust’s existence.”

Thanks for reading and more to follow later this week on Valard Construction Ltd. v. Bird Construction Co.

Doreen So

23 Oct

Charities and Applications to Pass Accounts – Do you need to serve the Public Guardian and Trustee?

Stuart Clark Passing of Accounts Tags: , , , , , , , , 0 Comments

You are the Estate Trustee of an estate in which the testator left a substantial portion of the residue to certain specifically named charities. The charities who are named as beneficiaries are well established large charitable organizations whom you have corresponded with directly. Such charities have retained counsel to represent them concerning their interests in the estate, and such counsel have in turn requested that you commence an Application to Pass Accounts regarding your administration of the estate.

In preparing the Application to Pass Accounts you turn your mind to who you should serve with the Application. Rule 74.18(3) of the Rules of Civil Procedure provides that an Application to Pass Accounts shall be served on “each person who has a contingent or vested interest in the estate“.

Although you are aware of the general supervisory role that the Office of the Public Guardian and Trustee (the “PGT”) has over charities in the Province of Ontario, as the charities in this instance are well established and represented by counsel, you question whether you need to serve the PGT in addition to the charities with the Application to Pass Accounts. It is, after all, the charities themselves who have a “contingent or vested interest in the estate“, and as the PGT and the charities would be representing the same financial interest you question whether it is necessary.

The requirement to serve the PGT with any Application to Pass Accounts where a charitable bequest is involved is established by section 49(8) of the Estates Act, which provides:

Where by the terms of a will or other instrument in writing under which such an executor, administrator or trustee acts, real or personal property or any right or interest therein, or proceeds therefrom have heretofore been given, or are hereafter to be vested in any person, executor, administrator or trustee for any religious, educational, charitable or other purpose, or are to be applied by them to or for any such purpose, notice of taking the accounts shall be served upon the Public Guardian and Trustee.” [emphasis added]

The requirement to serve the PGT with any Application to Pass Accounts when a charitable bequest is involved as established by section 49(8) of the Estates Act exists in addition to the general requirement to serve all individuals with a “contingent or vested interest” as established by rule 74.18(3). To this respect, when a Will leaves a bequest to a specifically named charity, the Application to Pass Accounts must be served upon the specifically named charity as well as the PGT. Although from a practical standpoint the PGT’s active participation in an Application to Pass Accounts where a charity is representing itself is unlikely, with the PGT deferring to the charity to protect their own interest, the service requirements remain nonetheless, and both entities could in theory participate in the Application to Pass Accounts, and both could in theory file separate Notices of Objection to Accounts.

Thank you for reading.

Stuart Clark

Can a Fiduciary Overcome Poor Record-Keeping?

Remedies for Breach of Trust on a Passing of Accounts

Passings of Accounts and Serving the Public Guardian and Trustee

29 Aug

Can a Fiduciary Overcome Poor Record-Keeping?

David M Smith Estate & Trust, General Interest, Guardianship, Passing of Accounts, Uncategorized Tags: , 0 Comments

The duties of a fiduciary must be performed diligently, with honesty and integrity and in good faith, for the benefit of the recipient.  Whether a fiduciary can prove that he or she has complied with these duties will depend to a great extent on the ability of the fiduciary to account.  While the duty to account is not debatable, the Court may consider the specific circumstances of the fiduciary when evaluating whether their actions are appropriate.

In Christmas Estate v Tuck [1995] OJ No 3836, the executor disputed numerous cheques for the benefit of the attorney for property and other cash gifts that she was unable to substantiate with receipts or vouchers. The Court held that it would be inappropriate to impose strict accounting requirements where the parties had a “close family relationship”, in this case, mother and daughter.

The Court further declined to draw a negative inference when the attorney was unable to produce records to account for all transactions: the grantee had helped the grantor “in a multitude of ways” and, accordingly, the burden of strict accounting practices was inappropriate.

In Laird v Mulholland [1998] OJ No 855, the Court noted that the overall credibility of an attorney for property is an important factor in determining whether that attorney’s informal accounts are satisfactory. The Court was unable to conclude that the attorney had acted dishonestly with a view to misappropriating the grantor’s assets, notwithstanding that his “record-keeping practices [left] much to be desired.

The Court pointed to the “abundant evidence” that the Attorney had performed “a multitude of services” which were entirely for the benefit of the grantor. The Court held that the fiduciary had acted “honestly and reasonably in all the circumstances” and should therefore be “relieved from personal liability.”

Thanks for reading,

David Morgan Smith

 

20 Jul

Can a Beneficiary Force an Interim Distribution from an Estate?

Hull & Hull LLP Estate & Trust, Executors and Trustees, Litigation, Passing of Accounts, Trustees Tags: , , , , , , , , 0 Comments

A question that I am often asked by both beneficiaries and Estate Trustees, is whether the Court can compel an Estate Trustee to make an interim distribution.

Beneficiaries and Estate Trustees are often at odds as to how quickly they wish to proceed with an interim distribution.  A beneficiary is generally eager to receive their entitlement from an Estate as soon as possible.  Estate Trustees, however, carry significant personal liability should they too hastily pay out Estate funds, and therefore tend to exercise caution before distributing.

In the decision of Parson v McGovern, a motion by a beneficiary (who had a one-half interest in the Estate) sought to compel the Estate Trustees to make an interim distribution of almost all of the remaining assets of the Estate to the beneficiaries.  The beneficiary requested that this distribution be made before the Estate Trustees passed their accounts (and obtained Court approval).

The Court considered the prior decisions in Re Blow, Brighter v. Brighter Estate, and others, and concluded that the following factors should be considered by the Court when deciding whether to compel an Estate Trustee to make an interim distribution to a beneficiary:

  • are the Estate Trustees deadlocked;
  • have the Estate Trustees acted with mala fides;
  • have the Estate Trustees failed to exercise their discretion to make an interim distribution;
  • have the Estate Trustees behaved unreasonably or breached their fiduciary duty and duty of good faith and fairness to the respondent (the beneficiary); and,
  • would a beneficiary suffer under undue prejudice.

In applying these factors to the case at hand, the Court considered, in part, that the Estate Trustees were not deadlocked, had proceeded to pass their accounts in an expeditious fashion, did not extort the beneficiary into signing a waiver/release, did not cause delay in administering the Estate, and there was no evidence the beneficiary would be unduly prejudiced if an interim distribution was not made.  Based on this, the Court did not compel the Estate Trustees to make an interim distribution, and the motion by the respondent beneficiary was dismissed.

Noah Weisberg

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11 Jul

Remedies for Breach of Trust on a Passing of Accounts

David M Smith Estate & Trust, Executors and Trustees, Passing of Accounts, Trustees Tags: , , , , , 0 Comments

Remedies for breach of trust are commonly sought in estate litigation, most notably in the context of a contested passing of accounts application.  An executor who mismanages the estate assets, makes a bad investment, or distributes to a stranger rather than a beneficiary can easily be found to be liable for either breach of trust or breach of fiduciary duty or both.

The remedies available to the disappointed beneficiary can, however, be complex.   AIB Group (UK) Plc v. Mark Redler & Co. Solicitors, a 2014 decision of the United Kingdom Supreme Court, provides a comprehensive multi-jurisdictional overview of this interesting area of law.

The case considered the remedies available to a bank when the solicitors it engaged to secure a loan against property failed to adequately secure the bank’s interest.  The Court noted that, in considering the remedies available for breach of trust, the Court must consider the different obligations of a trustee in order to evaluate the remedies that may be available for a given breach, such as:

(i) a custodial stewardship duty (to preserve the assets of the trust);

(ii) a management stewardship duty (to manage the property with care), and

(iii) a duty of undivided loyalty (prohibiting a trustee from taking advantage of his or her position without fully informed consent of beneficiaries).

What is interesting from the perspective of an estates litigator is the Court’s observation that, “historically, the remedies for such breaches took the form of orders made after a process of accounting.  The basis of the accounting would reflect the nature of the obligation.  The operation of the process involved the court having a power, where appropriate, to “falsify” and to “surcharge.”

Falsification is another word for “disallow”; the Court will “falsify” the unauthorized breach of the custodial stewardship duty and require the trustee to make good the loss to the trust.

Although the terms are less commonly referenced in modern practice, surcharge and falsification are great examples of how courts provide remedies for breach of trust in the context of a contested passing of accounts.

Thanks for reading.

David Morgan Smith

 

 

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