July 12, 2021 – Family Gifts As Income

“I am also not prepared to impute to the father an income on account of the monetary gifts he and his family have received from his parents.  In Bak v. Dobell, 2007 ONCA 304, 86 O.R. 3(d) 196, the Ontario Court of Appeal stated at para. 74:

Although it seems that legislature intentionally did not include the receipt of gifts given in the normal course in presumptive income, or as an example of an appropriate circumstance under s. 19(1), a court will consider whether the circumstances surrounding the particular gift are so unusual that they constitute an “appropriate circumstance” in which to impute income.

In considering whether it would be appropriate to do so, the Court of Appeal stated that a court had to consider the following factors:

–    The regularity of the gifts;

–    The duration of their receipt;

–    Whether the gifts were parent of the family’s income during cohabitation that entrenched a particular lifestyle;

–    The circumstances of the gifts that earmark them as exceptional;

–    Whether the gifts do more than provide a basic standard of living;

–    The income generated by the gifts in proportion to the payor’s entire income;

–    Whether they are paid to support an adult child through a crisis or period of   disability;

–      Whether the gifts are likely to continue;

–      And the true nature and purpose of the gifts.”

K.A.F. v. J.L.F., 2017 ONSC 4279 (CanLII) at 20-21