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Posts from the ‘Child Support’ Category

Despite Canadian Order, Court in India Refuses to Allow Child’s Return

Despite Canadian Order, Court in India Refuses to Allow Child’s Return

Given the impressive multiculturalism of modern-day Canada, it is not uncommon for parents to have originated from different nations before settling down to raise their children here.  But when those same parents later find themselves on the brink of separation or divorce, they may choose to return to their country-of-origin (often to rejoin extended family), and ideally take their children with them.

This can give rise to disputes involving numerous international law issues, including: whether a parent actually has the legal right to do so; which country’s laws and judicial system should govern the matter; where a trial or hearing should be held; and how or whether Family Law orders validly issued in one country can be enforced in a different one.

This last issue was the illuminated in a recent ruling from a court in India.  The decision shows that – as with the courts of all countries — the judgments of Canadian courts are not always respected and enforced, especially when they happen to relate to children.

The ruling emanated from the northern Indian state of Rajasthan, which borders on Pakistan.  Despite the existence of an order by a Canadian court requiring a 10-year-old boy to be returned from there to rejoin his father in Canada, the presiding Indian court concluded that the boy should not be allowed to go.

The boy’s parents, who had lived together in Ontario while married, were now embroiled in a custody dispute over him, post-separation.  The mother took matters into her own hands, and unilaterally decided to move the boy back to India with her, against the father’s wishes. This prompted the father to successfully obtain an order from Family Court judge in Hamilton, Ontario, granting him sole custody of his son, and directing his return.  That order also directed all law enforcement agencies – including INTERPOL – to take enforcement steps as necessary.

The matter then came before the court in India, where the father merely sought to have the pre-existing Ontario court order enforced.

However, the Indian court refused to do so, stating:

“If now he is forced to go back to Canada in the sole care of his father, is likely to psychologically disturb him, particularly when he will be required to now adapt to an education system of that country. This would adversely affect his over all growth and grooming as in the absence of his mother, his father being a busy professional, he is not likely to remain under the care of a Nanny.”

The Indian court was untroubled by the existence of the prior Canadian order stating otherwise; it concluded that it still had the authority to decline the boy’s return in light of what it adjudged to be his best interests.  That remained the prevailing and paramount consideration.

Indeed, the Indian court observed that the existence of the Canadian court order was “only one of the factors” and that it should not get “fixated” with it.   Rather, in these kinds of cases the India court had other factors to consider, too: – such as how settled the child had become in the new country, whether he or she would be exposed to physical or psychological harm, and whether the child’s own views could be ascertained in light of his or her age and maturity.

Applying those tests, the Indian court was satisfied that the child’s removal back to Canada to rejoin his father was not in his best interests in this case, since he had already been living in India for several years, and suffered from some health concerns.  (Still, the court did acknowledge the father’s access rights, by issuing directions specifically mandating that he still be allowed to maintain contact with his son.)

The court added that the boy should be allowed to stay in India until he reached the age of majority, at which time he would be entitled to choose between pursuing citizenship from that country, or else obtain citizenship rights in North America.

See the full text of the Indian court’s judgment, here.

 

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

 

Can Scam Immigration Marriage Be Annulled?

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Can Scam Immigration Marriage Be Annulled?

In this Blog we often focus on divorce, and its fall-out.   A topic that doesn’t come up often, is the effect of immigration fraud on the validity of a marriage.

This unusual issue was the focus in an Ontario case called Grewal v. Kaur, where on a motion for summary judgment the court was faced with the following question in its own words:

“Can immigration fraud, where one spouse has married the other for the sole purpose of acquiring citizenship status in Canada, unbeknownst to the other sponsoring spouse who thought they were entering into a genuine marriage and who was deceived as to the other spouse’s motivation for entering into the marriage, form the legal basis for the granting of an annulment of a marriage, if such can be proven at trial?”

In this case, the husband had been tricked into marriage by the putative wife. His lawyer argued that if for none other than public policy grounds, immigration fraud should be a ground for annulment to discourage anyone from “jumping the queue” in the Canadian immigration system.  It would also deprive the fraudster from being eligible for certain marriage-based remedies under Ontario family law.

The court rejected these policy-based arguments. It held that that changing the law around marriage and annulment would not impact the flow of the immigration system in the least, since the laws governing that regime already define “spouse” to exclude immigration fraudsters.   As for the impact on family law entitlement, the court noted that it is “difficult as a practical matter to conceive that family law remedies would be awarded to a proven immigration fraudster.”

The court also dismissed the added argument that cultural sensitivities might dictate expanding the law in this area, stating:

Certain individuals may be motivated by the belief that for cultural and/or personal reasons an annulment is preferable to a divorce.   While these beliefs may be sincerely held, I see no good reason to recognize a legal right to an annulment. The courts are already having difficulty dealing with the existing volume of pressing criminal, family and civil matters.  I see no public interest in adding to the caseload if the principal motivation relates to saving face or conceptions of personal or family honour.

More to the point, the court concluded that it was bound by several existing Ontario Court of Appeal decisions holding that immigration fraud cannot be relied on to grant an annulment, even where – as here – one spouse had tricked the other into marriage for the sole purpose of acquiring citizenship status in Canada.  If the prevailing caselaw on this point was ripe for being overturned based on public policy and related arguments, then this was a task that only the Court of Appeal itself could do.

In short, the court concluded that the grounds for granting an annulment have already been firmly set by legislation; there was no reason to try to expand them to include immigration fraud even where it involved deception of one spouse by the other.

For the full text of the decision, see:

Grewal v. Kaur, 2009 

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

 

 

Does Employer Discriminate Against Woman Who Lacked Child-Care?

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Does Employer Discriminate Against Woman Who Lacked Child-Care?

“Family status” is one of the prohibited grounds of workplace discrimination under the Ontario Human Rights Code.  It is defined as “the status of being in a parent and child relationship.”

The scope of an employer’s duty to accommodate an employee’s “family status” was the focus of a recent case called Peternel v. Custom Granite & Marble Ltd. where the court heard a human rights complaint by a woman who was returning to her job from having taken maternity leave.  She claimed the employer had discriminated against her by requiring her to report to work each day at 8:30 a.m., even though she had no morning child-care for two of her three children.  She claimed this was tantamount to a failure to accommodate her “family status” under human rights legislation, and asked for six months’ pay and $20,000 in punitive damages.

The woman had started to work for the small company – which made and installed granite counters — in 2010, taking on the role of scheduler.  And important part of her job was to respond to early-morning calls and attend morning meetings, and the woman acknowledged that an 8:30 a.m. start-time was one of the stipulations in her job description.  Still, during the years leading up to the birth of the woman’s third child, the employer had accommodated her child-related needs to some extent, for example by giving her a cellphone that allowed her to make work early-morning work-related calls from her home.

But in 2015, while the woman was still on maternity leave, the employer advised that upon her return she would be required to consistently report to work at 8:30 a.m., due to changes in the workplace. The employer gave her time to try to find child-care, but she was unable to do so in advance of her return date.

The employer did offer her an alternative job, at comparable pay, that would allow her to start work mid-morning, rather than at 8:30.   However, the woman did not even respond to that offer; instead she chose not to return to work when her maternity leave came to an end.

In light of these facts, and after pointing out some issues with the woman’s credibility, the court dismissed her discrimination claim.   The court concluded that she had essentially frustrated the employer’s efforts to accommodate her.

First, the court noted contradictions in the woman’s dealings with the employer, and some discrepancies in her evidence to the court.  For example, she had told the employer that she could not come into work by 8:30 a.m. because she needed to take her children to the school bus; however, the court noted the woman’s mother lived with them, and was often called upon to watch the children including taking early mornings when the woman’s job absolutely required it.

After shining light on further discrepancies, the court noted:

Taken as a whole, the evidence leads me to conclude that [the employer] Custom was a good employer to the plaintiff. Custom allowed the plaintiff flexibility with her hours, and showed her sympathy and accommodation following earlier miscarriages and throughout her last pregnancy. In return, Custom expected and understood that the plaintiff would be able to come to work in the early morning when required, and be willing and able to field early morning telephone calls from home or en route to work.

When it came time to accommodate her third child, the employer was ill-positioned since the woman had not provided key information concerning her need for accommodation, and not given details about her efforts to secure child care.

By law, all employees have a positive duty to cooperate with an employer as part of the human rights accommodation process, which includes providing information concerning family-related needs, and working with the employer to identify possible solutions.  In this case, the woman had simply failed to provide the employer with the information it needed to accommodate her.

For the full text of the decision, see:

Peternel v. Custom Granite & Marble Ltd., 2018 

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

 

 

 

Long-Overdue Divorce Act Amendments Are Likely On the Horizon

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Long-Overdue Divorce Act Amendments Are Likely On the Horizon

Canadian law has not seen a substantive change to the federal Divorce Act in more than 30 years.  But with the mid-2018 introduction of Bill C-78 (which has the unwieldy title of “An Act to amend the Divorce Act, the Family Orders and Agreements Enforcement Assistance Act and the Garnishment, Attachment and Pension Diversion Act and to make consequential amendments to another Act”) that long-overdue revision and update is in sight.

Bill C-78, which is expected to be passed into law in 2019, is touted as having a long list of legal substantive and procedural objectives, including:

  • Simplifying certain processes, including those related to family support obligations;
  • Creating duties for parties and legal advisers to encourage the use of family dispute resolution processes (including negotiation, mediation, and collaborative law);
  • Introducing measures to assist the courts in addressing family violence; and
  • Establishing a framework for the relocation of a child.

Importantly, the Bill also proposes to give clarity to what is considered the “best interests of the child”, by establishing a non-exhaustive list of criteria.  It also strengthens the court’s ability to focus on a child’s best interest when crafting its orders, by mandating that the court consider the child’s own views and preferences in the context of his or her age and maturity (unless those views cannot be ascertained in the circumstances).  This is in keeping with existing court rulings on the point, and essentially imports the established principles into a more modern version of the statute.

Bill C-78 also injects two important concepts into the existing legislation:

  • That part of fostering the “best interests of the child” requires a court to consider each parent’s willingness to support the development and maintenance of the child’s relationship with the other parent; and
  • That grandparents, or other persons who play an important part in a child’s life, may be eligible to obtain a court order formally entitling them to have contact with the child.

Finally, the Bill updates terminology throughout the existing Divorce Act, so that references to “custody” and “access” are replaced with terminology related to “parenting” and “decision-making responsibility” instead.

In a nutshell, the changes proposed under Bill C-78 are designed to clarify and promote some well-established family law principles (especially those relating to children), and to make the family justice system more accessible and efficient.  Further updates on these pending changes will follow in future Blogs, as the Bill gets closer to being passed.

At Russell Alexander Collaborative Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

 

Did Landlord Have Duty to Warn Woman of Fraudster Boyfriend?

Fraudster Boyfriend

Did Landlord Have Duty to Warn Woman of Fraudster Boyfriend?

In a decision called Larizza v. The Royal Bank of Canada, the court introduced the facts this way:

The [female] plaintiff … was the unfortunate victim of a [male] fraudster.  She met [the man] in February 2012, and married him in March 2013.  During the course of their relationship, [the man] persuaded [the woman] to sell her house, move in with him, and give him over two hundred thousand dollars. In the summer of 2013, she became aware that [the man] was not who he purported to be, and that she had lost the money she gave him.

When they had met online, the man told the woman he was a 56-year old wealthy Swiss-Canadian businessman, and heir to a fortune made from the Ovaltine beverage.   In fact, he was 69 years old, born in Egypt, and had been convicted of fraud on a number of past occasions.   When the woman finally confronted him about her money, he physically assaulted her, and was arrested. He was convicted of assault and fraud, and sentenced to 60 months in jail.

Their rental living arrangements while married became the focus of the woman’s subsequent legal claim against the landlord, Minto.

At the man’s urging, the woman had sold her house, quit her job, and moved in to the Penthouse of the Minto-owned building in which the man had previously rented a 9th floor unit.   That move came after the man single-handedly negotiated with Minto about the Penthouse rent and terms.  What the woman didn’t know, was that Minto had performed a credit check on the man, and finding there was “insufficient” credit information, had asked him to provide another name.  Without her knowledge, the man offered up the woman’s name and a credit check was done without her consent.  Based on her strong credit rating, Minto agreed to lease the Penthouse suite.

What the woman also wasn’t clear on at the time, was that she was listed as the tenant on the one-year lease calling for $10,225 in monthly rent.  She said she signed after being rushed into it by the man, and thought she was signing merely as an occupant.  In fact, the reverse was true.

She therefore sued the landlord Minto for damages, claiming it had a responsibility to take steps to: 1) protect her from the man’s fraud; and 2) alert her to the fact that she was actually the tenant on the hook for the hefty rent.  She argued that, based on Minto’s interactions with the man, and given his long history of fraudulent activities for which he had been previously convicted and imprisoned, Minto had a duty to protect her from the man’s fraud.

The court rejected the woman’s claim.  Even after seeing the man’s sketchy credit report, Minto did not have a duty to alert her about it in the time leading up to signing the lease.  Although Minto did have a duty of good faith and honesty in performing its end of the lease – by providing a habitable rental unit in exchange for rent – it also had no duty toward her in the time leading up to signing it.  Nor did it have any obligation to make it clear she was signing as the tenant, not the occupant.

Simply put:  Canadian law did not recognize a duty of care owed by landlords to tenants or potential tenants to protect them from third-party fraudulent schemes.  The court said:

There is no basis for a potential tenant entering into a lease to expect the landlord to protect him or her from the potential fraud of other people who will be occupants of the dwelling.  The reality is that it would be exceptionally intrusive for landlords to have an obligation to inquire into the legitimacy and wisdom of the decision of two people to live together.  This type of intervention bears no relation to the nature of the contractual relationship between the parties, and cannot give rise to an expectation that landlords would have such a duty.

The court added that even if landlords like Minto had such a duty, in this case any financial harm suffered by the woman was too remote. The court granted Minto’s motion for summary judgment, obviating the need to have the matter go forward to trial.

For the full text of the decision, see:

Larizza v. The Royal Bank of Canada, 2017

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

 

Court Comes Down Hard on Self-Represented Wife – And Orders $150,000 in Costs Against Her

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Court Comes Down Hard on Self-Represented Wife – And Orders $150,000 in Costs Against Her

On a recent ruling to allocate costs of the litigation between a former couple that lasted almost two decades, the court had some pointed comments about self-represented litigants in general, and about the wife’s unreasonable conduct in the case, specifically.

The court began its judgment this way:

A New Year

It is 2019, and Ian and Katherine Kirby, after 17 years, have a Final Order in their marathon matrimonial struggle.

There is one more battle to fight, however – costs.

The Judgment

The trial, more like a sentence than a sojourn, lasted ten days.  Katherine acted for herself, and she is responsible for much of the prolongation of the hearing.

Although the divorce itself was agreed upon, the court listed the many specific legal issues that needed to be resolved through litigation between the former couple.  Each spouse had been successful on some issues and not others, and some had garnered only “mixed” success.  Overall, however, the court concluded that the husband was more successful in the outcome than the wife, and that he was more deserving of costs.

The court then made some general comments about self-represented litigants:

The proliferation of self-represented litigants in family law cases is here to stay.  I suspect that there are many reasons for that: cuts to legal aid services, the self-help resorted to on the world wide web, and (let us not be so naïve to ignore) the voluntary choice by some litigants to act for themselves because they think that the judge will be forced into being their advocate.

With respect to the latter category of self-represented litigants, it is time that we recognize that there are some (not most, maybe even not many) persons who can readily afford legal counsel but simply choose to act for themselves because they think that it will provide them a tactical edge in the courtroom.  It will cause the presiding judicial official to go overboard with assistance, not just procedurally but substantively, or so goes the rationale.

There is nothing wrong with self-representation.  What is wrong, though, is hijacking the proceeding at the expense of the other side (who has counsel) and then expecting mercy from the court when it comes to deciding costs.

We do not have two sets of rules and principles for costs in family litigation – one for those who hire lawyers and one for those who act for themselves.

It then elaborated on what a court’s guiding principles are when awarding costs:

The principles apply to both types of litigants: (i) in deciding entitlement to costs, consider the presumption that a successful party deserves some costs, and consider the factors outlined in the Family Law Rules, and take into account any other relevant circumstance; (ii) in deciding quantum of costs, remember the basic tenet that the goal is to achieve something that is fair, just and reasonable, and keep in mind the prudent expectations of the parties, and pay attention to the importance of proportionality, and assess (but do not dissect line by line) the reasonableness of the time spent and the fees and disbursements charged.

The court added:

Above all, place some emphasis on why we award costs to begin with – to partially indemnify successful litigants, and to encourage settlement (even where the final result was worse than what the party offered to settle for), and to sanction and deter inappropriate conduct by litigants (even behaviour that falls short of “bad faith”).

The process by which we decide costs is not science.  It is more artful than that.  Consequently, there is an inescapable degree of arbitrariness to any costs award.  To pretend otherwise, I respectfully suggest, is a little rich.

The court then examined the spouses’ respective conduct during the course of the litigation.  In fairness, it noted that both spouses were responsible for the fact that the file languished for years and years. But it credited the husband for making greater efforts to settle without a trial, for being better prepared, and for behaving “much more admirably during trial”.

On the other hand, the wife’s conduct was unreasonable:  She made late-breaking “wild allegations” of being raped by her husband, and failed to comply with prior orders.  Even her submission on costs was filed late, after being granted an extension, and it did not comply with the court’s express directions on its length.  (The court read it nonetheless, as a courtesy).

As the court summed it up:  “She single-handedly caused the hearing to be significantly longer than it should have been” and her conduct in the past two years or so was “worthy of serious condemnation by this Court”.

It concluded that the case “out to have never went to trial,” and that “awarding to [the husband] every cent of the $190,438.63 is in the cards”.

However, the court noted that the wife is “indeed, mentally ill”, a fact confirmed by the family physician’s evidence, and surmised that some of her unreasonableness is due to her psychological issues.  Concluding that this militated against awarding the husband his full costs, the court reduced the total to an even $150,000, all-in.  Those costs were to be immediately deducted from the wife’s share of the proceeds of the matrimonial home.

For the full text of the decision, see:

Kirby v. Kirby, 2019

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

Family Judge Says:   “The Guidelines are Not a Price List”

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Family Judge Says: “The Guidelines are Not a Price List”

Many of or previous Blog posts have illustrated how the provincial Child Support Guidelines, and its federal counterpart, the federal Child Support Guidelines work in various factual contexts, to guide parents and judges in determining how much child support each separated or divorcing parent should pay.

In the past year alone, we have given examples of  how special expenses such as a child’s sports or extracurricular activities are dealt with; how self-employment income is accounted for in the calculations, and even how the Guidelines are to be used to calculate child support for adult children..

What should be abundantly clear from those many illustrations, is that when the matter of child support is placed before a judge, the Guidelines are merely a starting-point for what becomes a complex mathematical calculation that takes numerous factors into account.   This is why it’s often perplexing for separating parents to try to determine what support amounts are fair, when they don’t have the help of a lawyer to guide them.

The recent case called Vidal v. Dunn is an excellent example of the complexity and number of different that this exercise entails.  As we chronicled in prior Blogs on this case, the parents had a raft of child support-related disputes between them, including the question of whether their troubled teenaged daughter’s criminal defence bills – totalling over $10,000 – were considered “special or extraordinary expenses” to be shared by the parents, and whether their 20-year-old daughter was still considered to be a “child” for the purposes of being eligible for support.

In the context of making a ruling on this last issue, the court noted that both the federal Divorce Act and the Ontario Family Law Act apply the Guidelines, and both have comparable child support objectives.

But the court went on to make an interesting observation about the nature of the Guidelines themselves:  For one thing, they are more complex than a fixed-price menu, but also not amenable to “short cuts” even by a court.  As the court wrote:

The authority to order further child support is found in legislation. The Child Support Guidelines were intended to help separated families set child support in a fair and predictable way. The Guidelines are not a price list.  It can be very complicated, especially for adult children. Entitlement to child support is a prerequisite before determining quantum under the Child Support Guidelines. The statutory path is mapped out. The court cannot customize legislation with short cuts. 

In a very recent case called Henry v. Boyer, the court emphasized the point made in Vidal v. Dunn that the Guidelines are aimed specifically at helping “separated families” to set child support both fairly and predictably.  But there are many variables in that calculation, a point that newly-separated parents should keep in mind when trying to forge the path forward towards a divorce.  It’s always a good idea to seek the advice of an experienced Family lawyer.

For the full text of the decisions, see:

Vidal v. Dunn, 2018 

Henry v. Boyer, 2018

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com

 

On Income Tax, Support Arrears, and Retroactive Support

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On Income Tax, Support Arrears, and Retroactive Support

Income tax time will be upon us soon enough.  If you are receiving spousal support from your former spouse, you may wonder how those support payments should be treated when it comes time to file your income tax return with the Canada Revenue Agency.

The answer is straightforward:  If you are receiving spousal support from your former spouse or common-law partner, under a court order or written agreement that specifies the amount, frequency and duration of the payments, then those amounts are fully taxable in your hands.  In other words, all those amounts must be reported as “income” on your tax return, and will be taxed accordingly. (This is unlike the situation with child support, which from the recipient’s vantage point is generally considered non-taxable).

Normally, that obligation to declare your spousal support as income on your tax return triggers a corresponding entitlement by your former spouse or partner to claim an equivalent deduction on his or her tax return for those same payments, with some exceptions.

So the short answer, is that spousal support is considered “income.”  But what if the payments you receive now cover support payments that your former spouse should have made in the past?

A pair of recent decisions tackled a narrow – but important – issue relating to how: 1) retroactive support, and 2) support arrears, are to be handled for personal income tax purposes.

In a case from last year called Gonsalves v. Scrymgeour, the court reviewed the law on the tax treatment of retroactive spousal support awards (being those where the support paying spouse is newly-ordered to pay an amount that covers a past period of time during which the other spouse was eligible to receive it). The court confirmed that an award of retroactive spousal support should be reduced, to take into account the benefit of the income tax deduction that the paying spouse would have been able to claim, using the mid-point of the spouse’s respective marginal tax rates.

The more recent decision in Negin v. Fryers addresses support arrears (which are unlike retroactive support because they consist of unpaid amounts that were due under an order made previously).  There, the separated parents had agreed in 2004 that the father would pay child support to the mother in line with Guidelines amounts, together with a set amount of spousal support.   Apparently for some of the years since then, the father overpaid child support by over $52,000, and underpaid spousal support by more than $155,000.  After offsetting these amounts, the mother claimed the father owed just under $103,000 in arrears.

The father claimed – unsuccessfully – that the lump-sum gross amount he now owed the mother in arrears should be “netted down” to account for the different tax treatment of lump sum spousal support, as compared to an order for periodic support.  The wife pointed out – and the court agreed – that it was the policy of the Canada Revenue Agency to allow non-retroactive lump-sum spousal support payments to be deducted by father in the role of the support payor.  The court directed the parents to calculate the amount of child and spousal support owed or overpaid accordingly (as the case may be), in keeping with its specific directions and ruling.

Nobody loves tax time (except perhaps the Income Tax Preparers and Accountants!)  If you have questions about the spousal support you receive, feel free to give our office a call.

For the full text of the decisions, see:

Negin v. Fryers, 2018

Gonsalves v. Scrymgeour, 2017

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders.  For more information, visit us at RussellAlexander.com