The amount of past or future income loss may be proven using the “earnings approach” or the “capital asset” approach. The former will be more useful when a loss is more easily measureable – for example where a plaintiff’s income is not expected to fluctuate, up or down, over time. The latter is more useful when the loss is not easily measured: Perren v. Lalari, 2010 BCCA 140 at para. 32 [Perren].
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