G. Direct and Hidden Costs of Custodial Parent

• Author: Julien D. Payne - Marilyn A. Payne
• Pages: 265-265

Page 265

The designated expenses under section 7 of the Federal Child Support Guidelines refer only to third party expenses directly incurred by the claimant and not to any hidden costs incurred by a custodial parent,¹⁷¹although personal and hidden costs incurred by a such a parent may ground a claim for spousal support.¹⁷²

[171] See s. 7(2) of the Federal Child Support Guidelines which applies the respective incomes of the spouses as the guiding principle, not the value of their contributions. Compare Willick v. Willick, [1994] 3 S.C.R. 670, 6 R.F.L. (4th) 161 at 204.

[172] Moge v. Moge, [1992] 3 S.C.R. 813, 43 R.F.L. (3d) 449.