19 July 2017

Trust: Chang v. Lee

With details of $275,000 family funding for an Auckland house purchase at Sunnynook on Auckland’s North Shore never finalised, the transaction created rights of part-ownership ruled the Court of Appeal in a dispute between Chin-Fu Chang and his niece Hsing-En Lee.
Ties between the Chang and Lee families go back a long way.  They had joint business interests in Taiwan.  The Court of Appeal was told Mr Chang advanced $275,000 in May 2011 to help Ms Lee purchase a property at Stoneleigh Court, in Sunnynook.  Details of the advance were left to be sorted out later, but nothing eventuated.  When Mr Chang subsequently raised the issue, Ms Lee said the $275,000 was written off against a family debt he owed the Lees.  This argument was rejected in the High Court.  The trial judge said it was an interest free loan.  Mr Chang objected.  He said he was a part-owner, despite Ms Lee being registered as the sole owner.
The Court of Appeal ruled Mr Chang was a part-owner.  Where terms of an advance are not agreed, there is a presumption a trust exists creating part-ownership in the acquired property.  It is not for the courts to construct a loan agreement when no terms have been agreed, the Court said. 
Mr Chang holds a 48.6 per cent interest in the Sunnynook property, being the percentage of the purchase price he provided.  Ms Lee was given six months to buy out her uncle’s share at a fair price.  Failing that, the property is to be sold and the proceeds divided between them.
Chang v. Lee – Court of Appeal (19.07.17)

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