“In Fisher v. Fisher, 2008 ONCA 11, at paras. 105-106, the Court of Appeal noted the following framework from the Spousal Support Advisory Guidelines (“SSAG”):
a. A short-term cohabitation or marriage is one of less than 5 years;
b. A medium-term cohabitation or marriage is from 5 to 19 years;
c. A long-term cohabitation or marriage is 20 years or longer. However, a medium-term cohabitation/marriage becomes a long-term one if the parties’ years of marriage, plus the age of the support recipient at the date of separation, equals or exceeds sixty-five (“the rule of 65”).
An indefinite duration of spousal support is considered to be appropriate following the breakdown of a long-term marriage. The rationale is that, after a long-term marriage, the dependent spouse is often of an age that makes it difficult to achieve economic self-sufficiency. This same rationale applies to the rule of 65: Fisher, at paras. 35, 106.”