British Columbia, Canada
The following excerpt is from Mohamud v. Yu, 2016 BCSC 1138 (CanLII):
These factors must be considered in the context of each case in order to determine what a particular plaintiff would realistically have done in the future had the injuries not occurred. If the plaintiff proves a real and substantial possibility of a future event leading to an income loss, that loss may be quantified either on a capital asset approach (where the loss is not easily measurable) or an earnings approach (where it is easily measurable): Perren v. Lalari, 2010 BCCA 140.
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