Does a payor spouse have an obligation to disclose their income on an ongoing basis?
British Columbia, Canada
The following excerpt is from Z.D.D. v. R.C.G., 2004 BCSC 1239 (CanLII):
In the recent case of Hietanen v. Hietanen, [2004] B.C.J. No. 1584, 2004 BCSC 306, Mr. Justice Fraser, in a case with some parallels to this one, stated that, notwithstanding there being no positive obligation on a payor spouse in the Guidelines to disclose his or her income on an ongoing basis: ...parents whose incomes are relevant to the financial support of their children have an obligation to disclose changes in their income from time to time. This is based on the concept of utmost good faith. It does seem to me that the law should not hesitate to require that parents act with the utmost good faith toward their children. (¶ 16)
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