A liquidator or administrator of a company that is trustee of trust funds may be remunerated from those trust funds for work done in administering the trusts, but only for work properly attributable to trust administration, not for general liquidation work. The basis for such remuneration is the court's inherent equitable jurisdiction over trusts, supplemented by the Berkeley Applegate equitable principle. The procedure for fixing remuneration should follow the model used for court-appointed liquidators, with referral to the Registrar and opportunity for trust claimants to object.
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