In Francis v. Baker, 1999 CanLII 659 (SCC),  3 S.C.R. 250, Bastarache J., speaking for the court, considered the relationship between child support and spousal support at para. 41: In my opinion, child support undeniably involves some form of wealth transfer to the children and will often produce an indirect benefit to the custodial parent. However, even though the Guidelines have their own stated objectives, they have not displaced the Divorce Act, which dictates that maintenance of the children, rather than household equalization or spousal support, is the objective of child support payments.... While standard of living may be a consideration in assessing need, at a certain point, support payments will meet even a wealthy child’s reasonable needs. In some cases, courts may conclude that the applicable Guideline figure is so in excess of the children’s reasonable needs that it must be considered to be a functional wealth transfer to a parent or de facto spousal support.
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