When should the payment of this support begin? The leading case on retroactive support is Kerr v. Baranow, 2011 SCC 10, [2011] 1 S.C.R. 269, where the relevant factors are set out at para. 207: the needs of the recipient; the conduct of the payor; the reason for the delay in seeking support; and any hardship the retroactive award may occasion on the payor spouse.
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