What is the test for self-sufficientness in determining spousal support?

British Columbia, Canada


The following excerpt is from Schneider v Owers, 2019 BCSC 528 (CanLII):

Self-sufficiency is only one objective, and that goal is qualified “in so far as practicable”. In determining the “practicable” level of self-sufficiency, the court looks to the totality of the circumstances, including the recipient spouse’s age, gender, skills, education, opportunity for retraining, and the realistic prospects of finding a job that enables him or her to become self-sufficient (Tedham v. Tedham, 2005 BCCA 502). The claimant need not become self-sufficient immediately following a marriage breakdown, but she is “obliged to make reasonable efforts to achieve self-sufficiency” Hsieh v. Lui, 2017 BCCA 51 at para. 47. Absent reasonable efforts, a judge may impute income and reduce the amount of spousal support awarded.

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