“A court may also impute income where it finds that a party has hidden or misrepresented relevant information respecting a person’s income, either to the other party or to the authorities. This includes cases where the evidence indicates that a party earns cash income that they do not declare for income tax purposes, see: Kinsella v. Mills, 2020 ONSC 4785. For this reason, I am also prepared to impute an additional amount to Mr. Williams for his earnings as a repair technician, as well as factoring in the receipt of cash.
When additional income is imputed to a parent who engages in cash, the undeclared income is “grossed up” to take account of its tax-free nature, notwithstanding the payor’s liability to be reassessed by CRA, see Ali v. Williams-Cespedes, 2015 ONSC 3590.”
