August 6, 2019 – Obligations on the Self-Employed

“It is inherent in the circumstances of those who are self-employed or who have irregular income and expenses, that they have a positive obligation to put forward not only adequate, but comprehensive records of income and expenses. That does not mean audited statements. But it does mean a package from which the recipient spouse can draw conclusions and the amount of child support can be established. Where disclosure is inadequate and inferences are to be drawn, they should be favourable to the spouse who is confronted with the challenge of making sense out of financial disclosure, and against the spouse whose records are so inadequate or whose response to the obligation to produce is so unhelpful that cumbersome calculations and intensive and costly investigations or examinations are necessary. Nardea v. Nardea(heard March 5, 1998); MacLeod v. MacLeod, [1998] O.J. No. 3076  (Ont. Gen. Div.); Reyes v. Rollo, 2001 CarswellOnt 4541 (Ont. S.C.J.).”

Meade v. Meade, 2002 CanLII 2806 (ON SC) at 81