What is the test for calculating child support for adult children who are attending post-secondary education away from home?

Ontario, Canada


The following excerpt is from MacPherson v. MacPherson, 2005 CanLII 28543 (ON SC):

The case law is unsettled when it comes to calculating support for adult children who are attending post-secondary schooling away from home. In my opinion the court should assess whether post-secondary education expenses are, in the words of s. 3(2)(b) of the CSG, appropriate with respect to “the condition, means, needs and other circumstances of the child and the financial ability of each spouse to contribute to the support of the child” by considering the following non-exhaustive list of factors: (i) pre-break-up plans, (ii) necessity, (iii) effort and aptitude, and (iv) ability to pay. Some of these factors were identified in Farden v. Farden[4] which dealt with whether an adult child is entitled to support as a child of the marriage. (i) Pre-Break-Up Plans:

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