As L’Heureux-Dubé J. noted in Moge v. Moge, 1992 CanLII 25 (SCC),  3 SCR 813, 99 D.L.R. (4th) 456, at para. 84: A spouse may contribute to the operation of a business, typically through the provision of secretarial, entertainment or bookkeeping services, or may take on increased domestic and financial responsibilities to enable the other to pursue licenses, degrees or other training and education. To the extent that these activities have not already been compensated for pursuant to the division of assets, they are factors that should be considered in granting spousal support.
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