Tag: succession law reform act

12 Nov

En Ventre Sa Mere: Conceived But Not Yet Born

Paul Emile Trudelle Estate & Trust Tags: , , , , 0 Comments

Property rights of children permeate estate matters. Children can have rights under wills, on intestacy, as dependants, or under policies of insurance. They may have claims for damages against third parties under the Family Law Act.

A question often arises as to how far these rights extend. While living children may have such rights, what about the as of yet unborn?

Under the common law, children conceived but not yet born have the same rights as born children. “A fiction has developed in the law that in respect of property rights an unborn child who is subsequently born alive is in the same position as a child living at the time of death of the benefactor.”[1]

Thus, in Fitzsimonds, an unborn child who was born 8 months after the deceased’s death was entitled to an insurance payout even though the legislation required that she be alive 60 days from the insured’s death. The “legal fiction” of the “en ventre sa mere” doctrine is so strong that it would apply to legislation unless the legislation specifically provided otherwise.

The Succession Law Reform Act codifies the “en ventre sa mere” doctrine. Section 1.(1) defines a child as including “a child conceived before and born alive after the parent’s death”. To guild the lily, s. 46(9), dealing with intestate succession, provides that for the purposes of determining kinship, descendants and relatives “conceived before and born after the death of the deceased shall inherit as if they had been born in the lifetime of the deceased and had survived him or her.”

(The Succession Law Reform Act now extends the “en ventre sa mere” rule to children conceived after the deceased’s death, through artificial insemination. Certain conditions apply. However, that discussion is for another day.)

When addressing issues that arise upon a death, such as the distribution of an estate, policies of insurance or dependant support claims, keep in mind the rights of those “in the belly of their mother”.

Thanks for reading.

Paul Trudelle

[1] Fitzsimonds v. Royal Insurance Company of Canada, 1984 ABCA 7 (CanLII)

08 Nov

Preparing a Will? Consider This…

Sanaya Mistry Beneficiary Designations, Estate & Trust, Estate Litigation, Estate Planning, Executors and Trustees, Intestacy, Litigation, Wills Tags: , , , , 0 Comments

Life is unpredictable. Sometimes events happen that leave us speechless, whether we have just won the lottery or one of our loved ones has suddenly passed away. With all of the unpredictability life has to offer, one of the things we can actually plan for is what happens after our death.

This can be done by executing a Will. When thinking about your Will, there are many things to consider including your family and friends, your financial situation, and how you want your assets dealt with after death. The emphasis on these considerations may be different from person to person and as such, this blog focuses on three “big picture” questions that you should consider when thinking about your Will.

It’s important to know that in Ontario, if a person dies without having executed a Will, they die intestate and their assets are divided pursuant to the Succession Law Reform Act.

  1. Who will be the executor of your estate?

An executor (often referred to as an estate trustee) is a person that you can appoint in your Will to administer your estate. In other words, this person is responsible for fulfilling the terms of your Will, including but not limited to determining the value of your estate, paying your debts from the assets of your estate (if any) and distributing the assets of your estate as directed in your Will.

When choosing the executor, among other things, think about who would be able to fulfill the terms of your Will and be willing to take on this responsibility. An executor can be a relative, friend, or even a trust company. You can also have more than one executor and appoint alternate executor(s) in the event that the person you wish to appoint as your first choice is unable to act as executor.

  1. Who will benefit from your estate?

There are many ways to distribute the assets of your estate, including among others, by way of a specific legacy, a trust, or the distribution of the residue of your estate.

You may want to consider gifting a specific item or specific amount of money to any person. For example, you can gift a specific amount of money (such as $10,000) to each of your grandchildren or gift your books to your best friend. You can also give a specific item or specific amount of money to a charity.

You may need to consider setting up a testamentary trust, especially in the event that you wish to gift money to a minor.

You may also wish to distribute the residue of your estate (which is the remainder of your estate once all debts, liabilities and specific gifts are distributed) to one or more beneficiaries. You can choose to distribute the residue to your family (such as your spouse, children, parents, siblings, etc.), to friends and even to charities. You can also decide how much goes to each person. For example, you can choose to divide 50% of the residue between your parents and divide the other 50% of the residue between your siblings.

How you wish to distribute your assets is up to you! Although, if you are not dividing your assets equally among the same class of beneficiaries (for example, if you want one child to receive more than the other), this may lead to tension and possible litigation.

  1. What will happen if there is a common accident?

One circumstance that you may not consider but should likely pay attention to is what will happen if there is a common accident. For example, imagine a situation where you want the residue to be distributed to your spouse and in the event that your spouse predeceases you or dies within 30 days of your death, you want the residue to be divided equally among your children. As sad as it is to think about, how do you want your assets distributed in the event that a common accident occurs which results in the death of your immediate family? It is strongly recommended that you consider how you want your assets to be distributed in situations like these, even though the chances of this happening are likely very slim.

The above-noted information is not legal advice and simply highlights a few, very general points to consider when you are thinking about preparing your Will. It is recommended that you obtain legal advice from a lawyer who specializes in drafting Wills, so that they may be able to answer all of your questions and take into consideration your specific circumstances when preparing your Will. Remember, what works for one person may not work for another!

Thank you for reading.

Sanaya Mistry

02 Nov

Require a Certificate of Appointment? Consider These Upcoming Changes to the Probate Process

Sanaya Mistry Estate & Trust, Executors and Trustees, Trustees, Wills Tags: , , , 0 Comments

There have been many changes to the legal profession in the last year and a half. In Ontario estate matters, we have seen significant changes specifically to the process of obtaining a certificate of appointment of estate trustee, including the process of filing probate applications by email and the process of applying for probate for a “small estate”.

Another change, a substantial one, to the process of applying for a certificate of appointment of estate trustee becomes effective on January 1, 2022.

On October 15, 2021, Ontario Regulation 709/21 was filed, which amends the process of obtaining a Certificate of Appointment, as outlined in the Rules of Civil Procedure.

This new process, which comes into effect on January 1, 2022, streamlines the process of obtaining a Certificate of Appointment of Estate Trustee by revoking Rule 74.04 and Rule 74.05, and providing one set of requirements for applications with or without a will.

 

In addition, the applicant is required to serve every person entitled to share in the distribution of the estate, including charities and contingent beneficiaries, with (i) the application for a certificate of appointment (including any attachments), and (ii) if there is a Will, then a copy of the Will or Codicil. It should be noted that if the person is entitled only to a specified item or stated or determinable amount of money, a copy of the applicable portion of the Will or Codicil will suffice.

In streamlining this process, the content of 43 estate court forms have been consolidated into 8 new estate court forms and amendments have been made to 15 estate court forms, with a simpler format, better guiding language, and numbering the forms alpha-numerically for easier identification.

Further, this new process aligns the estate court forms with the Succession Law Reform Act amendments (which also come into effect on January 1, 2022), where spousal relationship information is collected with modifications to align with the recent legislative amendments relating to a will made prior to marriage and relating to a separated spouse’s entitlements.

It is expected that this new process will reduce costs and simplify the process of obtaining probate. As a result, the streamlining of this process will likely make it easier, cost effective and more accessible for those unfamiliar with estate administration to obtain a certificate of appointment of estate trustee.

Thank you for reading.

Sanaya Mistry

29 Jul

Options Available to a Surviving Spouse

Fred Tonelli Uncategorized Tags: , , , , , 0 Comments

In January 2021, a decision was made by the Ontario Superior Court regarding a motion in the ongoing Cohen v. Cohen Estate matter. This case involves a widow making a claim against the estate of her late husband on several grounds, including a decades-old marriage contract, an application for equalization of net family property, and a claim for dependent support.

As this matter demonstrates, a surviving spouse who believes themselves to have been unfairly left out of the will of their late spouse has several options in terms of litigation against the deceased’s estate. If a marriage contract existed between the spouses previously, providing for one spouse in the event of the death of the other, then the surviving spouse could move to enforce the marriage contract and make an appropriate claim upon the estate.

In the alternative, the surviving spouse can bring an application under the Family Law Act (“FLA”) to effect an equalization of net family property. This would be functionally similar to the process of asset equalization after a divorce or separation, only that the claim would be against the estate of the deceased spouse, rather than against their living person.

Also in the alternative, the surviving spouse can also bring an application under the Succession Law Reform Act (“SLRA”) for dependent support. Essentially, if the surviving spouse were to sufficiently prove to the Court that he or she was financially dependent upon the deceased while they were still living, then the surviving spouse could be entitled to an appropriate amount of cash to support their former lifestyle with their late spouse.

Finally, a surviving spouse can also make equitable claims of unjust enrichment, promissory estoppel, or proprietary estoppel. The essence of all three of these claims is that the deceased benefitted disproportionately from work that their spouse contributed to their relationship, and that the surviving spouse is therefore entitled to financial compensation, as a result.

Thank you for reading!

Fred Tonelli

13 Jul

British Columbia & Wills Variation: Who is Entitled to Dependant’s Support?

Rebecca Kennedy Support After Death Tags: , , , , , , , , , , , , , , 0 Comments

In Ontario, the Succession Law Reform Act, R.S.O. 1990, c. S.26 allows a deceased person’s dependants, to whom the deceased has not made adequate provision for his or her proper support, to seek an order for support to be made to the dependant out of the deceased’s estate. In order to qualify as a “dependant”, a person must be a spouse, parent, child, or sibling of the deceased “to whom the deceased was providing support or was under a legal obligation to provide support immediately before his or her death.” There are therefore several conditions for a person to be able to obtain an order for dependant’s support:

  1. they must have one of the required relationships with the deceased (spouse, parent, child, or sibling);
  2. the deceased must have been providing them with support, or have a legal obligation to provide support, immediately before the deceased’s death; and
  3. any provision made for the person in the deceased’s Will (if any) must be inadequate.

British Columbia deals with dependant’s support differently than Ontario. In B.C.’s Wills, Estates and Succession Act, S.B.C. 2009, c 13, s. 60 provides that if a testator does not make adequate provision for the proper maintenance and support of his or her spouse or children in his or her Will, the court may order the provision that it thinks adequate, just, and equitable in the circumstances for the spouse or children out of the testator’s estate. Unlike the Ontario law, it is not a requirement that the testator had been providing support to his or her spouse or children prior to death. This difference is significant because in Ontario, independent adult children are typically not able to obtain dependant’s relief as they do not meet the requirements of a “dependant”. In BC case law, there is also a greater emphasis on a testator’s moral duty to his or her dependant’s than there is in Ontario.

The BC Supreme Court decision in Jung v Poole Estate, 2021 BCSC 623 provides an example of how the difference in the law in Ontario vs. B.C. can result in vastly different outcomes.  In Jung v Poole, the testator was survived by his two twin daughters, Courtney and Chelsea. Courtney and Chelsea’s mother had been dating the testator when she became pregnant. The testator suggested an abortion but the mother chose to keep the twins, and raised them as a single mother without any involvement or financial assistance from the testator. The mother died when the twins were 4 years old, and a custody battle ensued between the testator and the twins’ grandmother on their mother’s side, on the one hand, and a couple who were friends of the mother’s and whom the mother had named in her Will to be the twins’ joint guardians, on the other hand. The testator expressed a desire to be involved in raising the twins at that time.

Ultimately, the court determined that the couple chosen by the mother to be the twins’ guardians would become the twins’ custodial parents. The testator and the grandmother were allowed specific and generous parenting time, access, and consultations regarding major areas of the twins’ lives. However, the testator never exercised any of these rights and, with the exception of one attempt to contact the twins the year after the custody decision, ceased to have any involvement in their lives.

The testator executed two Wills after the custody decision, both of which disinherited the twins. In one Will the testator referred to the twins as his illegitimate children, and in the other he explained that one of his reasons for disinheriting them was that they had not made efforts to contact him.

As stated by the court, if the court concludes that the testator owed a moral obligation to the twins and did not make adequate provision for their proper maintenance and support, the court has the authority to vary the testator’s Will to make the provision for them that, in its view, is adequate, just and equitable in the circumstances.

The court did ultimately conclude that the testator abandoned the twins from the outset, as well as after the custody battle, and had a strong moral obligation to them, which he failed to meet during his lifetime. As a result, the court varied the testator’s Will to provide 35% to each of Courtney and Chelsea, and 15% to each of the two friends of the testator who had been named as estate trustees and sole beneficiaries of his estate. The court was of the view that the testator had blamed the twins for the decision in the custody battle, even though that was beyond the twins’ control, and also blamed them for the lack of relationship, notwithstanding what the court found were valid and rational reasons given by the twins in this regard (including that they were hurt that the testator had wanted their mother to abort them, and the testator’s actions during their lives made it clear to them that he did not want them in his life).

It is unlikely that the same decision would have been reached had this situation occurred in Ontario. The fact that the twins were independent adults, and that the testator had not been providing them with support, nor under a legal obligation to provide them with support, immediately before his death, would likely have resulted in a decision that the twins were not entitled to support, regardless of the unfortunate circumstances between the twins and the testator.

Thanks for reading,

Rebecca Rauws

 

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28 Jun

Electronic Signatures Still not an Option for Wills in Ontario

Nick Esterbauer Estate Litigation, Estate Planning, Wills Tags: , , , , , , 0 Comments

Our readers will already know about the recent approval of legislation providing for will validation in Ontario under Bill 245, the Accelerating Access to Justice Act, 2021.  The act received Royal Assent in April 2021.  The changes under Schedule 9, which addresses amendments of the Succession Law Reform Act, RSO 1990, c S.26 (the “SLRA”), come into effect on January 1, 2022 (other than the update to virtual will witnessing in counterpart, which has already been made permanent under the revised Section 4 of the SLRA).

As of January 1, 2022, a new Section 21.1 of the SLRA will read as follows:

Court-ordered validity

(1) If the Superior Court of Justice is satisfied that a document or writing that was not properly executed or made under this Act sets out the testamentary intentions of a deceased or an intention of a deceased to revoke, alter or revive a will of the deceased, the Court may, on application, order that the document or writing is as valid and fully effective as the will of the deceased, or as the revocation, alteration or revival of the will of the deceased, as if it had been properly executed or made.

No electronic wills

(2) Subsection (1) is subject to section 31 of the Electronic Commerce Act, 2000.

Transition

(3)Subsection (1) applies if the deceased died on or after the day section 5 of Schedule 9 to the Accelerating Access to Justice Act, 2021 came into force.

We have seen Section 21.1 referred to as both a will-validation provision and as a “substantial compliance” provision.  In fact, Section 21.1 does not specify that substantial compliance with the formal requirements for a valid will under the SLRA is required and it may, accordingly be more accurately referred to as a will-validation provision.  Either way, this is a significant change to the law of validity of wills in Ontario and our province, as of January 1, 2022, will no longer be a strict compliance jurisdiction where some documents clearly intended to function as a valid will are rejected and deemed ineffective for technical reasons.

Notably, the legislation carves out the use of electronic signatures.  Some estate practitioners had been hopeful that electronic signatures would be accepted under the proposed estate legislative reform, given the recent increased acceptance of electronic signatures in the swearing/commissioning of affidavits and other legal documents and options available to verify their authenticity.  Section 31 of the Electronic Commerce Act, 2000, SO 2000, c 17, excludes the application of that act to wills, codicils, testamentary trusts, and powers of attorney.

Accordingly, it appears that a will signed by the testator or witnesses using electronic means cannot be validated by the Court, even after the new Section 21.1 is introduced to the SLRA.  For now (including after January 1 of next year), all wills still require actual, “wet” signatures in order to be valid.  Furthermore, even if a will may be validated by the Court under Section 21.1, the uncertainty, delay, and expense relating to applying for court-ordered validation of a will may still be best avoided by seeking an experienced estate planning lawyer’s assistance in the preparation of a Last Will and Testament.

Thank you for reading.

Nick Esterbauer

24 Nov

A Perceived Gap in Alberta’s Succession Law

Kira Domratchev Estate Litigation, Support After Death Tags: , , , , , 0 Comments

I came across an interesting report on Alberta’s succession law and what is perceived as a gap that has affected family maintenance and support in the province. The report was published by the Alberta Law Reform Institute (ALRI) and can be found here.

In accordance with the Family Law Act in Alberta, a child can apply for and may be entitled to support from a person standing in the place of a parent, when a couple separates. Under the Wills and Succession Act, however, which applies when a person dies, there is no provision addressing the distinction of a “person standing in the place of a parent”. What that means is that while a person who is characterized as a “person standing in the place of a parent” is alive, the child can apply for support under the Family Law Act but if this person dies, that same child has no ability to seek support from the Estate of this person “standing in the place of a parent”.

Consequently, the ALRI is of the view that there is a gap in the law that ought to be rectified on the basis of an equality argument, alone. This report was apparently recently sent to the province of Alberta but there has been no response, as of yet.

In comparing the provisions of the Succession Law Reform Act here in Ontario, it appears that the very issue raised by the ALRI is addressed by section 57(1) where the definition of a “child” includes a grandchild and a person whom the deceased has demonstrated a settled intention to treat as a child of his or her family, except under an arrangement where a child is placed for valuable consideration in a foster home by a person having lawful custody.” [emphasis added]

Certainly, it is important that children be able to bring a support claim against the estates of their parents, where not appropriately provided for out of the estate, even where not formally adopted but clearly treated as a child.

It will be interesting to see what happens and what the province of Alberta will do, if anything, in response to this report from the ALRI.

Thanks for reading!

Kira Domratchev

Find this blog interesting? Please consider these other related posts:

Perils in the Succession of the Family Cottage

B.C.’s Wills, Estates and Succession Act: Claims May be Pursued by Beneficiaries

Testing the waters of Section 72(1)(d) of the Succession Law Reform Act

30 Dec

The First Last Will

Hull & Hull LLP General Interest, Wills Tags: , , , , , , 0 Comments

With the new year approaching, it is customary to turn one’s attention to the year ahead in the making of resolutions.  In today’s blog though, instead of looking forward, I thought that I would look back – waaaaaayyyyy back – to the oldest Last Will and Testament.

The oldest last will and testament was discovered in 1890 by William Petrie, an English Egyptologist.  While exploring the pyramids in Kahun, Egypt, Petrie came across a parchment/papyrus from 1797 BC that was determined to be the last will of Ankr-ren.  The will was written in hieroglyphics.

Ankr-ren’s will left all of his property to his brother, Uah (who was stated to be a priest).

Uah’s last will was also discovered.  Uah’s will gifts the property he receives from Ankr-ren to his wife, Teta, forbids his wife from demolishing any house received by Ankr-ren, and names a guardian for his child.  The last will also had two witnesses.

Remarkably, or perhaps not, the terms of these ancient wills bear so many resemblances to modern day wills requirements found in Ontario’s Succession Law Reform Act.  For instance, they include the ability to freely gift property, to appoint a custodian/guardian for a minor child, and include two witnesses.

Noah Weisberg

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29 Jul

Who’s an Heir Under the Laws of Intestacy in Ontario?

Kira Domratchev Estate & Trust Tags: , , , , , 0 Comments

Most people know that if a person dies without a Will, the laws of intestacy govern the division of his or her estate. Specifically, it is Part II of the Succession Law Reform Act, RSO 1990, c S.26 (the “SLRA“) that is titled “Intestate Succession” that comes into play.

The question of who inherits where there is no Will is easily answered in some of the following scenarios:

  • Where there is a surviving spouse (limited to married spouses, by the way), said spouse is entitled to the entirety of the property of the deceased (section 45(1));
  • Where there is a surviving spouse and one child, spouse receives a preferential share of the estate of the deceased (i.e. $200,000.00 as of today) and if anything is left over, it is divided equally between spouse and child (section 46(1));
  • Where there is a surviving spouse and two or more children, the spouse is entitled to a preferential share of the estate of the deceased and 1/3 of what is left over. The remainder is then divided between the issue of the deceased (section 46(2)).

The SLRA further addresses how the division of assets is to take place where the only surviving relatives are parents, brothers and sisters and nieces and nephews (in respective order of preference). If the deceased has no surviving parents, brother/sisters or nieces/nephews, the next of kin provision (section 47(6)) applies.

Despite the fact that the SLRA attempts to bring clarity to the division of one’s intestate estate, it appears that certain situations may arise that would lead to confusion, absent case law that would provide some guidance.

In Farmer Estate v Karabin Estate, an executor of a niece who predeceased the deceased commenced an application in respect of her alleged share in the estate of the deceased. The Ontario Court of Appeal found that the SLRA is confined to nieces or nephews who do not predecease the deceased and does not extend to more remote issue. The Court of Appeal relied on section 47(4) of the SLRA which is worded as follows:

“Where a person dies intestate in respect of property and there is no surviving spouses, issue or parent, the property shall be distributed among the surviving brothers and sisters of the intestate equally, and if any brother or sister predeceases the intestate, the share of the deceased brother or sister shall be distributed among his or her children equally.” [emphasis added]

In interpreting this provision, the Court relied on the definitions of “child” and “issue” as defined in the SLRA, namely the definition of “child” includes a child conceived before and born alive after the parent’s death and the definition of “issue” includes a descendant conceived before and alive after the person’s death.

In another matter, Kiehn v Murdoch, the Ontario Superior Court of Justice found that grandnieces and grandnephews are excluded from sharing in the estate of a deceased by operation of section 47(4).

Unfortunately in the circumstances where a particular scenario arises that has not been clearly addressed by the SLRA and subsequent case law, an application for directions may need to be commenced to receive some clarity from the Court as to how a particular intestate estate is to be divided.

Thanks for reading!

Kira Domratchev

Find this blog interesting? Please consider these other related posts:

Common Law Spouses in Ontario and Intestacy

Intestate Estates and Mortgage Insurance

Does exclusion of family as beneficiaries of your estate preclude intestate succession?

13 Dec

Testing the waters of Section 72(1)(d) of the Succession Law Reform Act

Hull & Hull LLP Joint Accounts, Support After Death Tags: , , , , 0 Comments

Many of our readers will be aware that on an application for dependant’s support under Part V of Ontario’s Succession Law Reform Act, certain property that may not be considered an asset of the deceased’s estate can be “clawed back” into the estate for the purposes of considering and funding an award of dependant’s support.  Subsection 72(1)(d) provides that “a disposition of property made by a deceased whereby property is held at the date of his or her death by the deceased and another as joint tenants” shall be deemed to be part of the estate.

Whether jointly-held property is caught by s.72(1)(d) depends on whether there was a “disposition” into that joint tenancy.  When a property is initially purchased by a deceased person and another in joint tenancy and remains as such at the time of death, it can not be said that there was a disposition into joint tenancy: s. 72(1)(d) would not appear to apply.

However, when the ownership arrangement of a property is more intricate, whether or not jointly-held property will be deemed to be an asset of the estate within the context of a dependant’s support application becomes less clear.

Consider the following scenario:

  • At first instance, title to a property is taken as follows:
    • 50% held solely by A; and
    • 50% held jointly by A and B, who are common law spouses.
  • Years later, A conveys the 50% held by her alone to herself and her common law spouse jointly.
  • Therefore, immediately preceding A’s death, 100% of the property is held in joint tenancy by A and B.

Now, after A’s death, A’s minor children assert a dependant’s support claim. Does section 72(1)(d) apply, such that the property can be made available to fund a payment of dependant’s support?

The decision in Modopoulos v Breen Estate, [1996] O.J. No. 2738 interpreted section 72(1)(d) of the Succession Law Reform Act to mean that, only if the property was owned solely by the deceased and later transferred into joint tenancy prior to death, would there be a “disposition” into joint tenancy.

In the unique set of circumstances described above, it could be argued that A never solely owned the property and, therefore, the later disposition is not captured by section 72(1)(d).  However, another perspective is that the 50% interest held initially by A as a tenant in common (with A and B jointly as to the other 50%) would have formed part of her estate if the subsequent disposition to B as a joint tenant did not take place. This interpretation strongly supports that section 72(1)(d) of the Succession Law Reform Act would in fact apply to make the 50% interest in the property available in satisfaction of a dependant’s support claim.  Certainly such an argument is consistent with the remedial intent of the legislation.

To our knowledge, there has yet to be a decision in Ontario that addresses whether section 72 would apply to a disposition out of a tenancy in common and into a joint tenancy, such as that featured in our hypothetical example.  It will be interesting to see how a court would interpret similar transactions if encountered in the future.

Thank you for reading.

David Morgan Smith and Nick Esterbauer

 

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