What is the legal test for a management fee?

I respect the reasoning of Taylor J.A. in West v. Cotton (1995), 10 B.C.L.R. (3d) 74 (B.C.C.A.) with respect to the propriety of a management fee. The discount rate used in the calculation of the present value of various heads of damage is premised on the use of very conservative investments to obtain the required rate of return. The use of professional managers at a cost should be reflected in a rate of return which increases the net rate of return. That laudatory objective should not result in an increased cost to the defendant in view of the discount rate applicable in personal injury awards.