In Waters’ Law of Trusts in Canada, the authors, at Chapter 19(iv) s. A, cite as the leading Canadian case on the matter, Sanford v. Porter (1889) 16 O.A.R 565 (OCA). They cite it as authority for requiring a trustee to have his accounts always ready, to afford all reasonable facilities for inspection and examination, and to give full information when required. There appears to be no further requirement to report, nor any particular manner in which the trustee must keep his or her accounts.
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