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Presumption of Advancement

A presumption in trust, contract and family law which suggests that property transferred from a parent to a child, or spouse to spouse, is a gift and would defeat any presumption of a resulting trust.

In Re Levy, the Nova Scotia Supreme Court used these words:

"The presumption of advancement ... is the presumption of law that a spouse who purchases property and puts it in the other spouse's name or voluntarily transfers property to the marriage partner intends to make a gift and it is for the spouse making the transfer to the other spouse to prove there was no such intention.

"The presumption is based on the concept that where a property is transferred to a person to whom the transferor has an obligation to support, it is presumed to be an advance of the interest the dependent might reasonably expect to receive on the death of the transferor."

A presumption of advancement applies in regards to any purchase of property made in the name of the child or spouse of the puchaser.

The term has important application in family and estate law as it can significantly affect the determination and division of assets as between spouses or beneficiaries.

Lewin on Trusts, written in 1964, under the heading "presumption of advancment on purchases in the name of a child, wife or near relation" states:

"Where a (parent) purchases real or personal property in the name of his child, he is presumed to do so by way of advancement.

"The presumption of a resulting trust which would have arisen if the purchase had been made in the name of a stranger is rebutted and the property is presumed to be a gift.

"The presumption of advancement can, of course, be rebutted by evidence that no gift was intended....

"In the absence of evidence to the contrary, property bought by a husband in the sole name of his wife or intended wife is presumed to be a gift to her."

REFERENCES:

Mowbray, W., Lewin on Trusts (London: Sweet & Maxwell, 1964), pages 133-134 and 139. 

Re Levy 131 DLR 3d 15 (Nova Scotia Supreme Court, 1981)

See also Constructive and Resulting Trusts and Canadian Matrimonial Property Law - A Primer.

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Unless otherwise noted, this article was written by Lloyd Duhaime, Barrister, Solicitor, Attorney and Lawyer (and Notary Public!). It is not intended to be legal advice and you would be foolhardy to rely on it in respect to any specific situation you or an acquaintance may be facing. In addition, the law changes rapidly and sometimes with little notice so from time to time, an article may not be up to date. Therefore, this is merely legal information designed to educate the reader. If you have a real situation, this information will serve as a good springboard to get legal advice from a lawyer.

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