What is the test for using a valuation date other than the trial date?

British Columbia, Canada


The following excerpt is from Stevens v Stevens, 2019 BCSC 596 (CanLII):

In Kumagai v. Campbell Estate, 2018 BCCA 24, D. Smith J.A. held that using a valuation date other than the trial date constitutes a reapportionment. Therefore, it must be demonstrated that it would be significantly unfair to use the trial date:

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