July 20, 2023 – Intentionally Withholding Disclosure

“In instances where a party has intentionally withheld disclosure or has provided less than candid and/or complete disclosure, the court may, in imputing income, draw an adverse inference against that party, see Meade v. Meade, 2002 CanLII 2806 at para. 81 and see also s. 23 of the CSGThe policy rationale behind this rule is that a party should not be allowed to benefit from the deficient record they have created or caused by their failure to comply with disclosure obligations. This rationale is all the more pressing where a spouse is self-employed, and a determination of the spouse’s true income is directly contingent upon the completeness and accuracy of the financial disclosure.”

         Jean-Gilles v. Paculanang, 2022 ONSC 4264 (CanLII) at 59