This paper will explore the differences in Canadian common law and Québec civil law in relation to beneficiary-initiated variation and termination of trusts. Modification in Québec civil law focuses on giving proper effect to the intent of the settlor. This results in a far more restrictive regime than in common law Canada, which focuses on the rights of the beneficiaries. However, a rights-based model that recognizes beneficiary-initiated modification would also be compatible with Québec civil law.