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Can the Post-Bankruptcy Distinction Between Support and Equalization Payments be Circumvented?

Past Due

Can the Post-Bankruptcy Distinction Between Support and Equalization Payments be Circumvented?

Recently I wrote “How Does an Unpaid Equalization Payment Intersect with Bankruptcy?” about the impact that a paying spouse’s bankruptcy has on the recipient spouse’s entitlement to nonetheless receive either child/spousal support, or an equalization payment as part of a separation or divorce. I observed that – perhaps surprisingly – Canadian law treats these two categories quite differently in terms of the post-bankruptcy collectability by the recipient spouse.

Perhaps this distinction is why some courts might be tempted to try to re-cast a spouse’s entitlement, to maximize the possibility that his or her valid family law-related claim against the bankrupt spouse – essentially in creditor/ debtor roles – will be more likely to be preserved and enforced after the bankruptcy.

But as a case called Mwanri v. Mwanri illustrates, this re-characterization is not always appropriate or permissible in law.

After a trial, the husband and wife were granted a divorce, with the husband being ordered to pay the wife about $50,000 as an equalization payment. However, he filed an assignment in bankruptcy soon after, without ever having paid a dime in satisfaction of that obligation (his spousal and child support payments were current, however). It was unlikely that his assets would be sufficient to satisfy the amount he owed the wife in equalization.

In light of this and other developments, the wife applied to a motions judge for an order that his ongoing child and spousal support obligations be converted to a lump-sum amount in the same amount as the equalization payment would have been, i.e. $50,000. The motion judge agreed, ostensibly under a broad discretion to do so under the Ontario Family Law Act and the federal Divorce Act. The husband was discharged from his bankruptcy shortly after.

From a legal standpoint, the motion judge’s ruling effectively circumvented the distinction in law between the types of award: Unpaid equalization payments got swept into the husband’s bankruptcy and evaporated once he was discharged, while spousal support obligations did not. So by asking for a $50,000 lump-sum spousal award – which was the same amount she would have received in equalization were it not for the husband’s bankruptcy – the wife could enforce the award even after the husband was discharged. In other words, the motions judge simply converted the mother’s now-unenforceable equalization claim into an enforceable entitlement to lump sum spousal support.

The husband objected, and brought an appeal to the Court of Appeal, claiming that the judge’s award was tantamount to re-distributing the husband’s assets in favour of the wife and in preference to his other creditors.

The Appeal Court agreed with the husband. It found that when it came time to make the support award, the motion judge had failed to consider: 1) the father’s status as an undischarged bankrupt; 2) the effect of a lump sum spousal support award on the father’s ongoing bankruptcy, and 3) the implications of the father’s eventual discharge from bankruptcy on the parties’ financial circumstances and assets.

The lump-sum award – not coincidentally in the same amount as the equalization payment would have been – had been made without regard to the father’s impending bankruptcy, and amounted to an end-run around the normal operation of the bankruptcy legislation. Since this was impermissible, the motion judge’s earlier ruling was overturned.

For the full text of the decision, see:

Mwanri v. Mwanri, 2015 ONCA 843 (CanLII)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com.

Wednesday’s Video Clip: MIP – Process Mandatory for Divorcing Spouses in Ontario

Wednesday’s Video Clip: MIP – Process Mandatory for Divorcing Spouses in Ontario

In this video we take a look at the MIP program for the Ontario Family Court. All contested family cases are subject to requirements implemented by the Ontario Ministry of the Attorney General, obliging each spouse to attend a mandatory information program or session.

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com.

Is a Verbal Marriage Contract Only Worth the Paper It’s Written On?

Blank Paper

Is a Verbal Marriage Contract Only Worth the Paper It’s Written On?

In an interesting case from British Columbia, the court was asked to rule on whether a verbal marriage agreement, purporting to govern the division of a couple’s assets, was valid and enforceable.

The backstory featured a rather lavish courtship between a now 59-year-old doctor and a 49-year-old lawyer, who got married in Las Vegas in 2011. As part of their contentious divorce about three years later, the court heard that the husband had led the wife to believe that he was financially well-off; in the months prior to their wedding he had acted like a rich man, whisking her off to stay in 5-star hotels in destinations such as San Francisco, Palm Springs, Seattle, Europe, Los Angeles, Hawaii. In reality, he was overwhelmed with debt, owed money to Canada Revenue Agency, and had been repeatedly investigated and fined for improper billing in his medical practice.

Unaware of the true state of affairs, the wife proceeded with their wedding plans. At some point prior to the nuptials, she raised her concerns over a property she owned on Ross Street; she wanted it to be excluded from their family property, since it was her only asset and she wanted to have something for her children from a previous relationship.

They verbally agreed that the husband would not make a legal claim to it in the event they separated; the wife’s faith in his promise was fortified by her assumption that the husband was well-off in his own right. They had also discussed her understanding that under Canadian family law the Ross Street home would not become family property unless they lived in it together (which they did not intend to do, post-marriage, since it was rented to a tenant). They couple also agreed verbally to each pay their own credit card debts and their own car expenses, but share household expenses equally.

However, years of lavish and impulsive spending by the husband both before and during the marriage took its toll; after the inevitable financial collapse the wife was finally made privy to the true state of their precarious financial situation. The court described the next phase of their relationship this way:

She suggested to [the husband] that they move into Ross Street, but he would have to sign an agreement that recognized her sole right to that property and his sole obligation to pay his debts. [The husband] retorted that he would sign anything she wanted but she did not understand what it meant to be his wife. He suddenly asserted the marriage was over and he wanted a divorce. At the end of October 2014, [the wife] gave her Ross Street tenant notice and she moved into that home on January 1, 2015.

As part of the now-contentious divorce proceedings – and despite his verbal assurances to the contrary – the husband claimed against the wife’s Ross Street property nonetheless.

Ultimately the court issued a 132-paragraph ruling, which among other things considered in detail the provisions of the B.C. family legislation relating to division of property. The ruling culminated in a finding that the verbal agreement between the former couple to exclude the Ross Street home was valid and enforceable.

Among the evidence in favour of this conclusion was the fact that throughout their marriage they had acted in a manner that was consistent with the existence of such an agreement: the wife paid all the expenses related to the property and kept any income derived from it; the husband was never added on title, rarely attended at the property, and never made any financial or labour contributions to it (other than helping to power-wash the exterior on one occasion).

Although under Canadian law not all verbal agreements will necessarily be valid and enforceable, in this case the husband’s lack of credibility likely sealed the deal: In a preface to its ruling, the court underlined its finding that the husband “is not a trustworthy person”, that he had “little respect for the truth”, and that his evidence was “generally … unreliable and incredible”. This no doubt informed the court’s conclusion on the agreement’s existence, despite the husband’s unbelievable claims to the contrary.

For the full text of the decision, see:

Brown v. Brown, 2016 BCSC 1037 (CanLII)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com

We are pleased to announce that Laura will be returning to the team at Russell Alexander Collaborative Family Lawyers

Laura

We are pleased to announce that Laura will be returning to the team at Russell Alexander Collaborative Family Lawyers.

Laura’s enthusiasm and calm demeanour is an asset to the entire team, and her return has been much anticipated.

Welcome back, Laura!

Think You’re a Gift-Giver? Think Again

Gift Giver
Think You’re a Gift-Giver? Think Again

It seems like a straightforward scenario: Parents, perhaps now in their twilight years, decide to give a substantial gift to their married adult offspring, in the form of a large sum of money, land, a family cottage, or another asset (large or small). There is nothing in writing because – after all – it’s a gift between close family members.

But would it surprise you to know that absent a contract or other clear indication otherwise, the law actually presumes not that a gratuitous gift has been made from parent-to-adult child, but rather that the adult child holds the item/property on the parents’ behalf, unless there is evidence to the contrary?

The law on this perhaps confusing presumption was made clear in a recent Ontario decision called Barber v. Magee.

There, the couple had met in 2000, married in 2002, had a child together, and ultimately divorced in 2011. During the marriage, the husband had received $90,000 from his father toward the purchase of the matrimonial home, and another $67,000 later on. There was never a demand for repayment, nor any attempt to actually repay this $150,000 to the father. Nor were there any documents available: The husband claimed that his mother was the custodian of them, but had destroyed them in a “document purge”. He was thus unable to give the court evidence on the details of the purported loan, including the terms, interest rate, or repayment schedule.

Still, as part of settling their financial affairs during the divorce proceedings the husband claimed that this $150,000 was merely a loan from his father which he still had to repay; from a family law perspective this meant it would still form a liability and be deducted from his net family property.

As part of evaluating the husband’s position, the court revisited the current law on gifts-versus-loans in the context of these sorts of family law proceedings.

The court helpfully summarized the principles this way:

• In a scenario involving a gratuitous transfer of property from any one person to another (which for convenience we will still call a “gift”), the law of “resulting trust” applies. The law presumes that the actual intent of the gift-giver is to retain the gift but put in the hands of another person for “safekeeping” (so to speak), and not actually give it away.

• This also applies to gratuitous gifts between parents and adult children: The presumption is not that the parent intends a gift, but rather that the adult child is holding the property in trust for the aging parent. In other words, the assumption is that the gift-giving parents nonetheless hold an interest in the asset, even after placing it in the hands of the adult child.

• However, that presumption is rebuttable by putting forward evidence to the contrary. The burden is placed on the recipient adult child to show that an actual gift was intended, i.e. that he or she gets to keep the item.

• In the case of a dispute, the judge hearing the matter must begin with the presumption, and then weigh all the evidence in an attempt to determine the parents’ actual intent at the time of the transfer. The precise nature of the required evidence will depend on the facts of the case.

• There are various factors to consider:

o Whether there were any contemporaneous documents evidencing a loan;

o Whether the manner for repayment is specified;

o Whether there is security held for the loan;

o Whether there are advances to one child and not others, or advances on equal amounts to various children;

o Where there has been any demand for payment before the separation of the parties;

o Whether there has been any partial repayment; and,

o Whether there was an expectation or likelihood of repayment.

(A court will also take into account the fact that what started off as more of a “gift” to one spouse in a newly-separated couple may prompt the parents to suddenly collude in the claim it was a loan, to help out their son or daughter in the face of threatened litigation. This may be particularly so if the alleged debt is old, the parents do not need the money, and there has been no demand for repayment until after separation).

All of these principles stem from the law of equity, which focuses itself on what is fair. Those principles presume the existence of bargains, not gifts.

Returning to the Barber v. Magee facts, the court found that the $150,000 advanced from the husband’s father were gifts, with no clear intention or expectation that it be returned. Among other things, the court considered the fact that the wife had no idea during the marriage that the money was supposedly a loan; it was never discussed. She never saw or had knowledge of any documentation, and learned of the alleged loan only after she and the husband separated.

For the full text of the decision, see:

Barber v. Magee, 2015 ONSC 8054, 2015 CarswellOnt 19620, [2015] O.J. No. 6818

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com.

Wednesday’s Video Clip: Child Support and Different Custody Arrangements


Wednesday’s Video Clip: Child Support and Different Custody Arrangements

In this video we review how different custody arrangements affect child support obligations.

Shared custody

If each parent has the child at least 40% of the time, the Child Support Guidelines say there is “shared custody.” This refers only to the residential agreement, and should not be confused with the term “joint custody,” which refers to the parents’ joint right to make major decisions for the child. When there is shared custody, the amount of support paid to the parent with custody might be less than the amount set out in the table. Therefore, the term “shared custody” only refers to the amount of time spent with the child.

There is no formula in the Guidelines for determining how much time is spent with each parent in a shared parenting scenario. The onus is on the parent who claims they have shared custody to show that the child iswith him or her at least 40% of the time.

If the judge finds that the child spends at least 40% of their time with the parent who pays support, the Guideline table amount will no longer apply. Instead, the judge will look at the gross income of each parent to determine the child support amount, as well as theamount of time the child spends with each parent. This takes into account the reality of a shared parenting arrangement, because the more time the child spends with each parent, the more each parent is expected to provide basic items for the child, such as pajamas, toys, clothes, and bedding. Judges must consider these extra costs when they set support amounts for shared custody.

Split custody

Sometimes when parents with more than one child separate, one or more of the children will live with each parent. When this happens, child support depends on the income of both parents. How much support each parent would owe for any children living with the other parent is figured out according to the Guidelines. The parent who owes the higher amount must pay the difference between the two amounts to the other parent.

Take the example of one parent with custody of two children and an income of $25,000, and the other parent with custody of one child and an income of $45,000. According to the table, the parent with the lower income owes the other parent $211 a month in support for the one child who lives with that other parent. The parent with the higher income owes the other parent $680 a month in support for the other two children. When you subtract $211 from $680, the higher-income parent owes the other parent $469 a month in child support.

Sole custody

When a parent has sole custody of a child, this means that they are solely authorized to make major decisions for the child, to the exclusion of the other parent. In these cases, it makes sense that the child’s primary residence will be with the parent having sole custody. Therefore, to determine how much child support is to be paid, the courts are required to look to the Child Support Guidelines, which outline a table amount that is based on the payor parent’s income. The recipient parent’s income is irrelevant to this determination, as Child Support is the right of the child to receive. In some cases, the recipient parent’s income may be relevant, if there are special or extraordinary expenses to be shared above the Table amount. Since the Table amount is meant to cover only regular day to day expenses, such as food, clothing and shelter, any additional, or extraordinary expenses, are generally shared between both parents, proportionate to their incomes. Some examples of these expenses include daycare, dance lessons, and medical expenses not covered under a medical plan.

We hope you have found this video helpful. If you require further information about different custody arrangements please contact us.

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com.

Amelia Receives Client Service Award

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Amelia Receives Client Service Award

We are pleased to announce that Amelia recently received our Client Service Award for her excellent commitment to helping our clients.

Amelia’s attention to client service and her friendly prompt attention to detail makes her a valued member or our team. Congratulation Amelia. (pictured: Russell Alexander and Amelia Rodin)

How Does an Unpaid Equalization Payment Intersect with Bankruptcy?

bankruptcy

How Does an Unpaid Equalization Payment Intersect with Bankruptcy?

If one separated or divorced spouse is obliged, by agreement or court order, to pay the other spouse an equalization payment, there are various enforcement mechanisms that can be brought into play if he or she does not do so.

But what happens if the payor spouse goes bankrupt in the interim?

This question was addressed squarely by the Supreme Court of Canada in a case called Schreyer v. Schreyer. In particular, the Court considered the interplay between provincial Family Law statutory schemes on one hand, and the federal bankruptcy laws on the other.

Perhaps surprisingly, the Supreme Court concluded that any unpaid equalization payment is “swept into the bankruptcy” of the now-bankrupt spouse that has the payment obligation.

Effectively, this means the equalization claim by the recipient spouse is just like any other debt owed by the bankrupt spouse: In keeping with the regime established under the federal Bankruptcy and Insolvency Act, it becomes a claim that has to be proven just like any other claim put forth by a creditor (hopefully) for payment out of the bankrupt’s assets.

More to the point, in the context of the bankrupt spouse’s bankruptcy proceedings it cannot be put forward as a “preferred” claim, ranking ahead of other existing creditors. Rather, it may be one of many simultaneous debts owed by the bankrupt spouse, and will rank behind any secured creditors in priority.

(This certainly does not mean that a recipient spouse will not receive his or her equalization payment, or that the bankrupt spouse can try to avoid having to pay it under the guise of a bankruptcy. It just means that equalization claims don’t attracted any preferential status in the paying spouse’s bankruptcy proceedings).

And – no doubt to the chagrin of a spouse who is owed and expecting an equalization payment – the bankrupt spouse is released from that claim once his or her bankruptcy has been discharged in the usual manner.

Note that this outcome pertains to unpaid equalization payments only, which readers will know is the amount that spouses must pay to each other in order to equalize their respective Net Family Property as part of their division of assets.

However, in what may be a puzzling distinction, under Canadian family law the situation is entirely different for unpaid support claims and unpaid arrears in support: the bankrupt spouse is not released on discharge; rather, the payment obligation persists beyond the bankruptcy and is not erased.

I will touch upon the ramifications of this second scenario in a future blog.

For the full text of the cited decision, see:

Schreyer v. Schreyer, 2011 SCC 35, [2011] 2 S.C.R. 605 (S.C.C.)

Thibodeau v. Thibodeau, 2011 ONCA 110, 104 O.R. (3d) 161 (Ont. C.A.)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com.

Court Refuses to Sever Couple’s Divorce from Other Still-Disputed Issues

Divorce Issues

Court Refuses to Sever Couple’s Divorce from Other Still-Disputed Issues

When a marriage breaks down, the former couple is left to sort out a great number of issues between them in the short term. These often include matters such as child custody, access (and related scheduling), restrictions on relocating the child, interim financial support (both relating to child support and spousal support), plus decisions relating to their mutual assets, such as who gets temporary possession of the matrimonial home, and who gets possession of any recreational properties, etc.

The list goes on and on.

The question sometimes arises whether it’s possible – or desirable – to isolate or “sever” the divorce judgment itself from all other claims in litigation between the couple, as a means of “speeding up” that part of the process, to let the couple move on with that aspect of their personal lives. This question arises most often where there are a lot of complex and contentious issues that are unlikely to get resolved anytime soon.

In a recent Ontario case, the court made an unusual – though not unheard-of – ruling: it refused to sever the divorce itself from the other disputed matters. This was despite the fact that it was a high-conflict uncoupling; it was also despite the fact that the husband was now in a new relationship and simply wanted to move on with his life.

However, under the Family Law Rules, the court is only authorized to sever the divorce from the other issues where it concludes that: a) neither spouse will be disadvantaged by it; and b) reasonable arrangements have been made for the support of any children of the marriage.

In this case, the children were well-provided for, so that was not an issue. But the court found that the wife would suffer a disadvantage if the divorce were granted now because she would lose the medical benefits to which she was otherwise entitled as a “spouse” under the husband’s current medical plan.

It was true that the husband claimed that the wife would be covered under his group insurance plan nonetheless, and in any case promised to arrange to keep her covered until trial, either way.

But the court found that the husband had not met the legal burden of proving that this was definitely the case: a letter he provided from the medical plan’s benefit specialist did not persuade the court with sufficient certainty. (And the court pointed out that the husband could have easily met that burden by providing it with a copy of the relevant group insurance plan, so that it could assess whether the wife would still meet the definition of “spouse” in the event that they divorced. However – for whatever reason – the husband had chosen not to.)

As it happened, the wife had a number of health-related conditions, which it all the more prejudicial to her if the benefits ceased with the divorce Order. However, the court added that “even if [the wife] was completely healthy, the loss of medical coverage would still be prejudicial and disadvantageous.”

The court accordingly refused to sever the divorce from the other issues.

For the full text of the decision, see:

Shawyer v. Shawyer, 2016 ONSC 830 (CanLII)

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com

Wednesday’s Video Clip: Top 5 Questions About Spousal Support in Ontario, Canada

Wednesday’s Video Clip: Top 5 Questions about Spousal Support in Ontario, Canada

In this video we review some of the more common questions about spousal support in Ontario, including:

1) What is spousal support?

Spousal support — which is sometimes called “alimony” — is money paid from one spouse to the other after the dissolution of the relationship. The obligation to pay spousal support is a legal one, and may arise either from a marriage, or from a common-law relationship.

2) What is the legal basis for obtaining spousal support?

The obligation for one spouse to pay spousal support to the other does not arise automatically from the fact that the parties had a relationship together (whether formally married or common law). Rather, the spouse who is claiming spousal support must prove an entitlement to it.

A court may order spousal support, and will set an amount and duration based on various factors that exist between the parties. The jurisdiction for a court to award spousal support comes from either the federal Divorce Act (as part of a divorce order), or from the Ontario Family Law Act.

3) What factors dictate the duration and amount of spousal support?

The determination of how much support a spouse should receive, and for how long, is a complex equation. In making a spousal support order courts consider several factors, including:

• the length of the entire relationship (including time living together before marriage);

• the financial circumstances of each spouse, both during the relationship and
after separation;

• the functions performed by each spouse during the relationship;

• the financial repercussions or detrimental financial effect on one or both spouses of caring for each other or for any children of the relationship; and

• each spouse’s ability to support him or herself.

In some cases one spouse may have suffered a financial loss or disadvantage as result of joint career and lifestyle decisions made during the marriage or relationship (for example the decision to move the family so that a spouse can take a new job, or that the mother will give up her career to stay home and raise the children). A disadvantaged spouse will be entitled to support to compensate him or her for that setback.

There may also be a limit on the duration of the support that one spouse receives from the other, as means of encouraging the recipient spouse to achieve post-separation financial independence as quickly as possible. Alternatively, the order may contain a built-in review mechanism.

Note that there are certain tax consequences relating to spousal support — both from the payor’s and the recipient’s perspective. In short — and provided it is paid pursuant to either a written separation agreement or a court order — it is considered “taxable income” in the hands of the spouse who receives it, and is deductible from the taxable income of the spouse who pays it. These tax ramifications are taken into account when determining the amount of support.

4) How does the spouse’s behaviour affect spousal support entitlement?

Generally speaking, the entitlement to spousal support is not dependent on the spouse’s pre- or post-separation behaviour, morality, or ethical conduct. In other words, a spouse who is otherwise entitled to spousal support after the dissolution of a marriage will not become disentitled because he or she was violent, or because it is later discovered that he or she had an extra-marital affair during the marriage.
Having said that, a court’s determination of the amount and duration of spousal support will hinge upon each party providing forthright, comprehensive financial disclosure to each other. If in making the determination the court feels that one spouse has withheld financial information (e.g. has failed to disclose a source of significant income), the court may impute income to the spouse and award the other spouse his or her support accordingly.

5) What happens if there is a change in circumstances?

As indicated above, the notion of one spouse receiving spousal support from the other is rooted in several concepts and principles, including:

1) the financial disadvantage or dependence that relationship gave rise to must be redressed post-separation; and

2) the ability of the paying spouse to fund the spousal support award must be taken into account.

The amount or duration of spousal support may have to be adjusted if there is significant change in the financial circumstances of either party. This change must be significant, and must not have been foreseen when the separation agreement or the court-ordered spousal support award was made.

We hope you have found this video helpful. If you require further information about spousal support please contact us.

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at RussellAlexander.com