“N. began to attend university in person in the fall of 2021. That September, he began to live in St. Catherines for eight months of the year. As a result, Mr. Niro moved to vary the child support for N. based on decisions such as Coghill v. Coghill, 2006 CanLII 28734 (Ont. S.C.) and Liscio v. Avram, 2009 CanLII 43640 (Ont. S.C.). The approach in those cases was summarized by Price J. in Liscio, at para. 36:
The proper approach, in these circumstances, is the one taken by this Court in Coghill v. Coghill, at paras. 44 to 53. In that case, Justice Wright calculated the child’s expenses during the eight months the child was at university, deducted the contribution the child was able to make from summer earnings, apportioned the net expenses between the parents in proportion to their respective incomes and required them to pay their respective shares directly to the child. He then calculated the table amount of the non-residential parent’s obligation to pay child support for the four summer months, when the child was living with the residential parent, as if the child were a minor, based on the income imputed to the non-residential parent and required him to pay that amount to the residential parent. [Citations omitted.]”