Tag: Suzana Popovic-Montag

30 Dec

Top Estate, Trust and Capacity Cases of 2015: A Year in Review

Suzana Popovic-Montag Capacity, Estate & Trust, Trustees Tags: , , , , , 0 Comments

As 2015 comes to a close, the usual lists compiling the top songs, movies and books of the year seem to be everywhere. Accordingly, it seemed only appropriate to follow suit with our own list of the top estate, trust and capacity cases of 2015 from across Canada.

#1: Bunn v Gordon, 2015 ONSC 4768

The deterioration of the relationship between Estate Trustee(s) and beneficiaries may necessitate the removal of the Estate Trustee(s). As such, careful consideration to pre-existing relationships and personality conflicts should be given when making an Estate Trustee appointment.

Click here and here to read our previous blog posts on this case.

#2: McConnell v McConnell, 2015 ONSC 2243

By categorizing an RESP as a trust held by a trustee (parent) for the benefit of the beneficiaries (children), the court held that removal of a co-trustee (spouse) may be appropriate in certain circumstances, such as when the co-trustees can no longer cooperate effectively.

Click here to read our previous blog post on this case.

#3: McLaughlin v McLaughlin, 2015 ONSC 3491

The court approved the principles of Smith v Vance in determining what qualifies as a “financial interest” for the purposes of the Rules of Civil Procedure and the Estates Act. The court also affirmed that a financial interest includes an interest derived from intestacy and that being a child of the testator on its own is not enough to pass the threshold of having a financial interest.

Click here to read our previous blog post on this case.

#4: Mroz v Mroz, ONCA 171

Evidence of a testator’s intentions remains key in the rebuttal of the presumption of resulting trust.

Click here to read our previous blog post on this case.

#5: Dueck v Chaplin, 2015 ONSC 4604

The court declined to exercise its discretion to remove the Estate Trustees after they tried to renounce. This was due to the fact that the Estate Trustees had already begun to administer the estate and were viewed as having “intermeddled”. Accordingly, they had a duty to propound the will.

Click here to read our previous blog post on this case.

#6: Moore v Getahun, 2015 ONCA 55

The Court of Appeal overturned the lower court ruling that stated that it is improper for counsel to assist an expert witness in the preparation of his/her expert report.

Click here to read our previous blog post on this case and here to listen to the podcast.

#7: Park v Myong, 2015 ONSC 2287

A look at conflict of laws within an estate law context shows that a determination that the court has jurisdiction over one issue in a case will not necessarily ensure that is also has jurisdiction over another separate issue in the same case.

Click here to read our previous blog post on this case.

#8: Estate of Forbes McTavish, 2015 BCSC 774

Communication between co-Estate Trustees is an important aspect of their fiduciary obligations and avoidance of such can warrant removal.

Click here to read our previous blog post on this case.

#9: Burkhardt v Burkhardt Estate, 2015 ONSC 2688

The court looked at the definition of “common habitual residence” to determine entitlement to a spouse’s estate (with respect to equalization claims). The court found that the “last common habitual residence” referred to under the Family Law Act referred to the place where the spouses recently lived as husband and wife and where they last participated in every day family life together.

Click here to read our previous blog post on this case.

#10: Heston-Cook v Schneider, 2015 ONCA 10

Unsuccessful parties to a claim against an estate that may have lacked appropriate standing can obtain blended costs awards (in certain circumstances). Here, partial indemnity costs were awarded against the unsuccessful beneficiary and the balance was payable from the estate.

Click here to read our previous blog post on this case and click here to listen to the podcast.

#11: Carter v Canada, 2015 SCC 5

Physicians are allowed to assist patients in ending their lives in certain circumstances. The SCC struck down s. 241(b) of the Criminal Code which imposed a legal ban on physician-assisted suicide.

Click here and here to read our previous blog posts on this case and click here to listen to the podcast.

#12: Spence v BMO Trust Company, 2015 ONSC 615

The court held a will to be invalid for public policy concerns. Specifically, the court found the will to be discriminatory as the evidence suggested that the testator had disinherited one daughter for having a mixed-race child.

This case has been appealed but the decision from the Court of Appeal has not yet been issued.

Click here, here, and here to read our previous blog posts on this case and click here to listen to the podcast.

This list is by no means exhaustive; however, it does provide an overview of many of the estate, trust and capacity issues that were considered by the courts over the course of the year.

Thank you for reading and Happy New Year!

Suzana Popovic-Montag

23 Dec

Cherry Picking

Suzana Popovic-Montag Estate & Trust, Executors and Trustees, Passing of Accounts, Trustees Tags: , , , , , 0 Comments

When a trustee breaches his or her fiduciary duties, there are various remedies available to the beneficiaries. For instance, if a trustee makes an unlawful disbursement of trust funds and these funds are traceable, there may be a proprietary remedy. In other cases, when the funds are not recoverable, the beneficiaries may have recourse to a personal remedy against the trustee.

These types of claims are most often channeled through the obligation to account. In requiring a trustee to provide a full and complete accounting, the beneficiaries are able to review transactions and determine whether any of them go beyond the trustee’s parameters. This is why a trustee must always be prepared to provide records and account details if requested by the beneficiaries.

In reviewing a trustee’s accounts, the beneficiaries are accorded with a great deal of discretion with respect to accepting or rejecting any unlawful transactions. For instance, if a trustee breaches his or her fiduciary duty by engaging in an unlawful act which results in a financial loss, the beneficiaries can disallow the disbursement and it will not form part of the trust accounts. They can then seek a remedy to have the missing funds replaced – either through tracing or by the trustee personally. This may occur in a situation where a trustee uses trust funds to make an imprudent investment that s/he did not have the authority to make. If the investment does not succeed, the beneficiaries can strike it from the  accounts.

Alternatively, if the same investment results in a profitable outcome, the beneficiaries can choose to adopt the act and reap the benefits, notwithstanding the fact that the initial act itself was unlawful. In this case, the proceeds of the transaction are treated as trust property or if the trustee no longer has the funds, he or she can be required to restore the value of the proceeds to the trust.

This mechanism provides the beneficiaries with the best of both worlds. Even if there is one profitable act and another that is not (resulting in the trust assets breaking even by cancelling one another out), the beneficiaries can choose to adopt the profitable act and disallow the other. This can cause a windfall gain in some situations. The fact that the beneficiaries have this choice showcases that the law in this area can be very beneficiary-oriented.

Thank you for reading.

Suzana Popovic-Montag

 

16 Dec

Guardianship and Refugees

Suzana Popovic-Montag Guardianship Tags: , , , , , 0 Comments

As a result of the ongoing conflict in Syria, we are currently seeing one of the worst humanitarian crises in the world today. The United Nations has estimated that approximately 13.5 million people need urgent help, including 6.5 million people who have been displaced.

With human rights violations at the heart of the crisis and over 250,000 deaths so far, the Government of Canada has made the decision to implement a plan to work with private sponsors, non-governmental organizations, provincial, territorial, and municipal governments to settle 25,000 Syrian refugees here in Canada. The Government’s plan currently gives priority to vulnerable people who have registered with the United Nations Commissioner for Refugees (“UNHCR”) including women with children, unaccompanied minors, and the elderly.

The United Nations Children’s Fund reported in 2014 that of the displaced persons, approximately 8,000 were children that had fled Syria without their parents. This number has likely only increased since then as the conflict continues to intensify. As a result, it is important to bear in mind that many of the new arrivals may consist of unaccompanied minors and that in some cases, the appointment of a suitable guardian may need to be considered. In the cases where a guardian is required, it should be arranged as soon as possible.

According to the UNHCR, guardianship is a fundamental element in the protection of unaccompanied minors. The guardian’s responsibilities include ensuring that the child’s needs are being met until a more permanent arrangement for the minor can be implemented. This applies to the child’s physical, psychological, social, cultural, legal, medical, and educational needs.

In Canada, each province is primarily responsible for matters related to the reception and integration of unaccompanied minor refugees, including the appointment of a guardian. These practices can vary significantly from one province to another. For instance, in Ontario, it is the Children’s Aid Society and the Catholic Children’s Aid Society that provide child protection services for minors (up to the age of sixteen). However, in order for these agencies to be authorized to act as guardian to a child, a formal wardship order from the Ontario Court is still required.

It is important to note that the appointment of a guardian is not the same as a designated representative under the Immigration and Refugee Act who acts solely for the purpose of representing the unaccompanied minor in proceedings before the Immigration and Refugee Board.

Thank you for reading.

Suzana Popovic-Montag

09 Dec

Testamentary Capacity and Suicide

Suzana Popovic-Montag Capacity, Uncategorized, Wills Tags: , , , , 0 Comments

According to the World Health Organization (“WHO”), someone around the world commits suicide every 40 seconds. The suicide rate for Canadians, as measured by the WHO, is 15 per 100,000 people. Research also shows that although suicide typically arises as a result of the interaction between multiple factors, mental illness, specifically depression, is often present. This is why when a cause of death is suicide and it occurred close in time or in conjunction with the making of a will, there may be some question as to testamentary capacity.

One of the most common concerns is whether the mental illness or depression was severe enough to bring into question the testator’s testamentary capacity. Often, a person suffering from severe depression may feel isolated or rejected from loved ones. This may cause them to be more prone to making certain last minute testamentary dispositions that are not in accordance with family obligations or that deviate sharply from a previous will.

In these situations, the response from the courts has been to continue to apply the test for testamentary capacity as set out in Banks v Goodfellow. As Paul Trudelle points out in his paper, “Suicide, Suicide Notes, and Testamentary Capacity”, while the fact of suicide is admissible as a consideration, it is not conclusive.

Another issue is raised when the deceased leaves behind a suicide note that doubles as their last will and testament. This situation may bring into question issues surrounding formal requirements as well as potential interpretation concerns. The courts have gone back and forth on upholding these notes as valid wills as it is not always clear whether the note is an  expression of the deceased’s testamentary intent or merely precatory.

Thank you for reading.

Suzana Popovic-Montag

02 Dec

Unitrusts

Suzana Popovic-Montag Estate & Trust, Trustees Tags: , , , , , 0 Comments

The “even hand rule” is often found at the core of trustee obligations. This is because one of the most fundamental duties of a trustee is to treat different classes of beneficiaries equally and without preference. Often, this entails finding the balance between preserving the capital of a trust for the capital beneficiaries while maximizing income revenue for income beneficiaries. Obviously, this can be a challenge as the interests of capital and income beneficiaries can be  inherently opposed to one another. While one class seeks to preserve the trust assets, the other may prefer to engage in riskier investments in order to stimulate higher revenues.

The use of a unitrust (also known as a percentage trust) can be used to mitigate this problem. A unitrust is a trust in which a fixed percentage of the total value of the trust property must be distributed by the trustee in a predetermined period. Although the percentage payment is made from revenue generated by the trust, if there is insufficient revenue to make the payment, the difference is paid from the capital. Any revenue that is generated in excess of the percentage is added to the capital.

In this way, the trustee’s duty is no longer limited to preserving capital while maximizing revenue. The duty under a unitrust is to increase the value of the entire trust for the benefit of both classes of beneficiaries. This is accomplished by providing the trustee with much wider discretion as to making trust investments with the idea being that it will increase the overall value of the trust. It also allows the trustee to distribute funds without being overly concerned about whether the funds are stemming from income or capital. In removing this distinction, and the even hand rule concerns that come with it, the trustee is left free to optimize the value of the trust as a whole.

The concept of the unitrust is not a new one by any means. It was endorsed as far back as 1984 by Ontario’s Law Reform Commission in its Report on the Law of Trusts. Although they are not widely used, these arrangements can be seen in trusts of significant value where the settlor seeks an arrangement in which the trustee’s investments are not hindered by balancing class interests.

The unitrust is not without its own set of challenges. In times of economic downturn or when risky investments fail to yield anticipated results, the trust may not generate sufficient revenue to cover the fixed percentage payable to the income beneficiaries. Under these circumstances, there may be no choice other than to liquidate capital assets in order to meet the requirement. As a result, there is a risk of depleting the value of the trust up to its full amount prior to the right of the capital beneficiaries ever materializing.

Potential solutions to this dilemma have included drafting techniques which account for periodic downturns. For example, in “The Percentage Trust- Uniting the Objectives of the Life Tenant and Remainderperson in Total Return Investing by Trustees”,  Anne Werker suggests including a “force majeure” clause. These types of mechanisms provide the trustee with an established process in which he or she can periodically review and revise the percentage payable. Implementing these techniques can be critical in ensuring that unintended consequences do not arise.

Thank you for reading.

Suzana Popovic-Montag

25 Nov

Constructive Trustee

Suzana Popovic-Montag Estate & Trust, Executors and Trustees, Trustees Tags: , , , , , 0 Comments

When a trustee has breached his or her fiduciary obligations, the beneficiaries have access to a wide variety of potential remedies. However, a challenge arises when the person who improperly deals with the trust assets is effectively a stranger to the trust.

There are two types of remedies that can be applied in this latter scenario. The first is a proprietary remedy which requires that the trust property (or a traceable substitute) is being held. As long as the trust interest can be traced, it will subsist through the transfer of property. The only person against whom it cannot be claimed is a bona fide purchaser for value without notice.

The second type of remedy is personal in nature. If the third party is not a trustee, it can be difficult to attribute personal liability. To rectify this problem, the third party can be designated by the courts as a constructive trustee.

It is important to note that a constructive trustee is not the same as a trustee of a constructive trust; the most significant difference being that if a third party is found liable as a constructive trustee, he or she can be found to be personally liable. In contrast, if a constructive trust is found, the third party simply holds the property in trust for the beneficiaries. (Waters’ Law of Trusts in Canada, 4th Ed at 11.II)

According to the rule stated in Barnes v Addy (1873–74) LR 9 Ch App 244, there are generally three circumstances in which a third party can be found to be liable as a constructive trustee. These are:

Dishonest Assistance – This is a situation in which a third party assists the actual trustee in committing a breach or trust. In this sense, a legal fiction is created whereby the third party is designated as constructive trustee in order to impose a personal remedy. The standard here can be somewhat subjective but it typically requires actual dishonesty. Although carelessness may be a factor, the third party should have knowingly and intentionally taken part in the breach for the designation of constructive trustee to apply (Air Canada v M & L Travel).

Knowing Receipt of Trust Property – This situation arises when a third party accepts trust property from the trustee knowing that the funds are being given in breach of trust. This has been viewed by the Supreme Court of Canada in Citadel v Lloyds Bank as being akin to unjust enrichment claims with restitution being the appropriate remedy. However, the English courts have viewed it more as an equitable wrong such as conversion where the remedy is one of compensation or disgorgement.

Trustee de son Tort – This finding arises when a third party is essentially acting as the trustee (i.e. the constructive trustee) with all of the duties and obligations that this entails.

The concept of the constructive trustee has stepped in to create a remedy for situations in which a third party is responsible for a breach of trust. Despite not having a fiduciary duty to the beneficiaries, the courts have been generally unwilling to allow these individuals to escape liability and as a result, have shown that the obligations of a trustee may nonetheless be imposed upon a third party under certain circumstances.

Thank you for reading.

Suzana Popovic-Montag

18 Nov

Virtual Real Estate

Suzana Popovic-Montag Estate & Trust, General Interest Tags: , , , , , , 0 Comments

Massive multiplayer online role-playing games (“MMORPGs”) are estimated to generate $11 billion in annual revenues by the end of this year, representing roughly 21% of the worldwide digital games market. By 2017, this number is forecast to grow to $13 billion and their popularity only seems to continue to grow. For instance, World of Warcraft, a popular MMORPG, had over 10 million subscribers as of November 2014.

By way of background, many of these games implement a virtual economy. A player can earn or buy virtual items, property, or currency to be used in the game which can grow to have a significant economic value. As this Forbes article explains, in another popular MMORPG game, Entropia Universe, Jon Jacobs successfully sold a virtual space station he had created for $635,000. In order to make the initial purchase of the virtual asteroid which cost him $100,000, Jacobs took out a mortgage on his home. The investment clearly paid off, with his virtual property making him over half a million dollars in profit in just five short years.

Although most virtual world portfolios are not as impressive as Jacobs’, many gamers have accumulated significant assets by way of smaller purchases (including virtual real estate) that all together can make up a valuable virtual asset with real world economic value. The challenge that this creates is that these virtual economies exist solely at the discretion of the companies that run them. As this article points out, holding assets in virtual property, such as World of Warcraft gold or virtual real estate, is incredibly risky. There is simply no guarantee that the game will not be shut down or that the company will not debase the currency with an update or expansion.

These unusual assets raise unique issues for the estate practitioner. Primarily, how far do we need to go to ensure that all assets have been properly identified and valued in applying for probate? It is not difficult to imagine the repercussions of neglecting to include real property in a probate application. However, it is less clear when dealing with virtual real estate, despite the fact that it could potentially have significant value. In some cases, the deceased’s family may be unaware of the virtual holdings or of the fact that they have a real world value outside of the game. In other cases, there may be challenges with obtaining passwords to access the virtual assets.

We also need to be alert to potential liability issues. In including an asset such as a virtual financial portfolio that may contain virtual real estate, proper valuations may need to be obtained. This is not unlike many other unique real world assets, especially when the value is potentially significant or unclear. This may involve advising a client to seek the assistance of a professional valuation. Misstating the value of an asset, virtual or otherwise, can have significant tax implications.

As the notion of digital assets continues to expand, it is important to be aware of the different types of assets that a testator may hold upon death. Virtual real estate and other virtual financial holdings can have real world value and as such, should not be discounted as irrelevant.

Thank you for reading.

Suzana Popovic-Montag

 

11 Nov

If You Are Reading This…

Suzana Popovic-Montag General Interest, Wills Tags: , , , 0 Comments

It is estimated by Veterans Affairs Canada that during the first half of the 20th Century, more than 110,000 Canadians died in the line of duty. Countless others were wounded; many critically. Sadly, many more courageous women and men in the armed forces have since given their lives or been wounded in various missions around the world.

The risks and dangers of enlisting in the armed forces are inherent in the job. According to Defence Administrative Orders and Directives issued by the Canadian Armed Forces (“CAF”), CAF members are strongly encouraged to make a Will upon enrolment or update an existing one. Regardless of the assets the member may have upon enrolment, there are Death Benefits that may be payable to the family. If no beneficiary has been designated, these benefits are payable to the estate.

During the first half of the 20th Century, 1.7 million Canadians were called upon to serve their country. As a result of the urgency, most did not have the luxury to properly consider their estate plans beforehand. This gave rise to what is sometimes referred to as the “Battlefield Will”.

The Battlefield Will is a hastily drawn Will that does not need to meet some of the formal requirements as a result of the conditions under which it is being made. The Succession Law Reform Act has given effect to this principle under section 5, which can be read about in more detail in Ian Hull’s previous blog post on the subject.

It was also common for the Will to be accompanied by a final letter to be opened only in the event of death. These letters were written beforehand and sometimes contained testamentary dispositions. If no Will was made or the letter was all that could be located, these letters could sometimes be held to be valid testamentary documents.

These final letters have not been limited to soldiers of the 20th century. In 2007, Guardsman Neil Tony Downes, who died while on duty in Afghanistan at the age of 20, wrote to his girlfriend:

Jane, I hope you have a wonderful and fulfilling life. Get married, have children etc. I will love you forever and will see you again when you are old and wrinkly! I have told my parents to leave you some money out of my insurance, so have fun babe. OK… gonna go now beautiful. Love you forever.”

In other cases, the letters simply serve as a final expression of love for their family and to provide comfort upon receiving news of their death. For instance, from his dugout at The Somme in 1916, 20 year old Second Lieutenant Eric Heaton wrote to his parents:

“My darling Mother and Father, I am writing this on the eve of my first action. […] I cannot quite express my feelings on this night and I cannot tell if it is God’s will that I should come through – but if I fall in battle then I have no regrets save for my loved ones I leave behind.”

In honour of Remembrance Day, we remember the sacrifice that so many have made. We keep the men and women who have died in service to their country in our memory and give our thanks to not only them but to all those who continue to serve today.

Lest we forget.

Suzana Popovic-Montag

04 Nov

No-Fault Inheritance

Suzana Popovic-Montag Elder Law, Estate & Trust, Ethical Issues, Public Policy, Uncategorized Tags: , , , , 0 Comments

Public policy performs an important role in estate law. Among other things, it may remedy situations where the bequests contained in a will or pursuant to the laws of intestacy would lead to a result that offends Canadian values.

For instance, it is well settled in Ontario that someone who murders another person cannot benefit by inheriting their estate. They are also precluded from receiving any insurance proceeds. However, in common law Canada, depriving a murderer of such benefit (also known as the “common law slayer rule”) is as far as the Courts have been willing to go.

In contrast to civil law jurisdictions around the world (including the province of Quebec here at home, as well as many states in the United States) and subject to public policy considerations, common law Canada has stuck firmly by its system of no-fault inheritance.

The primary concern with having a no-fault inheritance regime is that we sometimes end up with absurd results. For example, imagine the child abandoned by one parent as an infant. Should that child die intestate as an adult without a spouse or children of their own, that same parent (if alive) could be entitled to either half or all of the estate.

Outside of common law Canada, this is traditionally where the doctrine of unworthiness to inherit has stepped in. In Quebec, these rules are codified in the Civil Code of Quebec.

Article 620 provides:

The following persons are unworthy of inheriting by operation of law:

(1) a person convicted of making an attempt on the life of the deceased;

(2) a person deprived of parental authority over his child, with the exemption for the child from the obligation to provide support, with respect to that child’s succession.

Article 621 adds:

The following persons may be declared unworthy of inheriting:

(1) a person guilty of cruelty towards the deceased or having otherwise behaved towards him in a seriously reprehensible manner;

(2) a person who has concealed, altered or destroyed in bad faith the will of the deceased;

(3) a person who has hindered the testator in the drawing up, amendment or revocation of his will.

Perhaps one of the most common uses of these rules has been as an alternative to undue influence claims. Undue influence is notoriously difficult to prove and often, while it is clear that there has been some influence and even some pretty reprehensible behaviour in caring for an aging parent, the claim falls short of reaching the higher standard of coercion.

In this way, the unworthy to inherit principle has been able to step in and look not only narrowly  at the influencer’s role in causing the will to be drafted but at the behaviour displayed towards the older person throughout their entire life. This widening of the net, so to speak, has been an important recourse in addressing the growing problem of elder abuse.

As discussed in my previous article, the U.S. has also moved towards the termination of inheritance rights for certain marital misconduct, including abandonment, abuse, and even adultery in some states. Whether this will be extended to non-spousal relationships, as is the case in most civil law jurisdictions, remains to be seen.

Thank you for reading.

Suzana Popovic-Montag

14 Oct

Voluntary Disclosure Program and Estate Trustee Liability

Suzana Popovic-Montag Estate & Trust, Executors and Trustees Tags: , , , , 0 Comments

Engaging the personal liability of an Estate Trustee is always a concern when administering an estate. In particular, Estate Trustees must be cautious to ensure that the deceased’s debts have been paid and that there are sufficient funds to pay any final taxes before any distributions are made.

In some cases, Estate Trustees may inadvertently find themselves in a situation where the deceased was not meeting their tax obligations to the Canada Revenue Agency (CRA”). This may be the result of simple carelessness resulting in failure to file previous returns, incomplete information, errors and omissions, or it could also be as serious as deliberate tax evasion. Either way, the Estate Trustees must tread carefully because if they choose to ignore these past discrepancies and distribute the funds, they may be held personally liable for the penalties and interest incurred.

Fortunately, CRA has created the Voluntary Disclosure Program which can be especially useful for Estate Trustees in this type of situation. The Voluntary Disclosure Program allows the taxpayer (or Estate Trustee) to come forward and voluntarily correct any errors or omissions without being subject to penalties (or prosecution) that would normally apply. According to subsection 220(3.1) of the Income Tax Act (ITA”), CRA may also waive a portion of the applicable interest with regard to assessments from the preceding ten years.

In order to benefit from the penalty and interest exemptions, the disclosure must meet the following four criteria to be considered valid. The exemptions are not automatic and are subject to the review of each request on its own merits:

  1. The disclosure must be voluntary. This means that it must be made prior to becoming aware of any compliance actions being taken;
  2. A penalty would apply;
  3. The disclosure must be complete; and
  4. The information being disclosed must be at least one year past due.

It is also important to note that disclosure can be made anonymously (commonly referred to as no-name disclosure). No-name disclosure is often preferred as it provides the Estate Trustee (or taxpayer) the opportunity to discuss the facts and tax issues with CRA while remaining protected. However, it should be kept in mind that it is not possible to reach any binding agreement under the no-name process. The Estate Trustee (or taxpayer) is given 90 days to release the name which would result in a further extension to submit any materials.

Under a named disclosure, the taxpayer is identified immediately, which prompts CRA to allow for 90 days to submit any additional materials without the limitation clock starting to run.

The Voluntary Disclosure Program can sometimes be a delicate process. As a result, before starting this process, professional legal or tax advice is always recommended.

Thank you for reading.

Suzana Popovic-Montag

SUBSCRIBE TO OUR BLOG

Enter your email address to subscribe to this blog and receive notifications of new posts by email.
 

CONNECT WITH US

CATEGORIES

ARCHIVES

TWITTER WIDGET