Is there any case law in Canada where a child care provider has been ordered to pay child care costs in cash rather than cash?

Ontario, Canada


The following excerpt is from K.H. v. T.K.R., 2013 ONCJ 418 (CanLII):

To the contrary see: Mundle v. Mundle, [2001] N.S.J., No. 111(NSCS). While I appreciate that the payor obtains the benefit of a discounted child care cost, and the reality is that many people deal with child care providers in cash, the courts should not be condoning the recipient’s complicity in tax avoidance by the child care provider. The court prefers to follow the Northwest Territory line of cases.

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