When will the court order the disclosure of income tax returns of a self-employed husband and wife?

British Columbia, Canada


The following excerpt is from N.V.G. v T.M.G., 2017 BCSC 1686 (CanLII):

As to the redaction of the respondent's income tax returns, I was told that the respondent files his return jointly with his spouse, and that what has been redacted is information concerning her income only. This is not like the situation before the court in Ackerman v. Ackerman, 2016 SKQB 353, where there was a possibility of income splitting between two self-employed spouses, necessitating the disclosure of the new spouse’s income tax returns. The application respondent in that case was ordered to provide a copy of his tax return that revealed his new spouse’s income, although he was allowed to redact her social insurance number. In the present case, however, the respondent is a salaried employee. There is no evidence before me suggesting that the redacted income tax returns delivered by the respondent do not provide a sufficient basis for determining his child support obligation. I decline to make the direction the claimant seeks.

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