Bedrossian – Court of Quebec finds that an estate became resident in Nova Scotia when a Nova Scotia executor was appointed

In 2012, the ARQ commenced the administration of the estate of a Quebec individual who had died intestate as provisional liquidator (i.e., executor) for the Quebec Unclaimed Property Directorate, since no claim had been made against the estate. In September and October 2017, the heirs of the estate (all siblings of the deceased) signed a deed naming Bedrossian (resident in Nova Scotia) as the executor. In October 2017, Bedrossian forwarded the appointment documentation to that Directorate.

The ARQ requested and reviewed documentation, then transferred the assets to Bedrossian in April 2018.

In April 2024, the ARQ assessed the estate for tax on a pension cheque that the estate had received in June 2017. The estate appealed that assessment on the basis that it was resident in Nova Scotia throughout 2017, as Bedrossian was resident there on December 31, 2017.

Before allowing the estate’s appeal. Sauriol JCQ noted that s. 28 of the Unclaimed Property Act (Quebec) stated that the “administration of the Minister terminates by operation of law” when “the heirs … are able to discharge the office of liquidator”, and then stated:

When Mr. Bedrossian submitted the deed of designation appointing him as the liquidator of the succession, he was then "able to discharge the office of liquidator".

The ARQ's request for additional documents for verification purposes did not alter the legal effects arising from the appointment of a liquidator. These legal effects occur automatically, without any voluntary intervention, and solely by operation of law.

Neal Armstrong. Summary of Bedrossian v. Agence du revenu du Québec, 2026 QCCQ 4316 under s. 2(1).