A.C.S. v. C.J.S.

A.C.S. v. C.J.S.

The court excluded the GoFundMe donations from the claimant's Guideline income and found the claimant's Guideline income commencing October 1, 2025 to be CAD 32,552 (employment insurance). The court imputed annual income of CAD 175,000 to the respondent (CAD 100,000 employment income and CAD 75,000 dividends) because of inadequate disclosure, inconsistent lifestyle with reported income and evidence of income manipulation; applied the Guidelines and relevant authorities to compute ongoing support of CAD 2,821 per month from October 1, 2025. The review effective date is June 19, 2024; the court declined to order retroactive support payable by the claimant to the respondent for July 1, 2024...

Citation
2026 BCSC 149
Parties
Claimant: A.C.S. also known as A.C.M.; Respondent: C.J.S.
Court
Supreme Court of British Columbia
Jurisdiction
Canada
Judgment Date
29 January 2026
Procedural Posture
Family Law Child Support Review and Variation / Decision on Review Applications (reasons for Judgment)
Outcome
Applications allowed in part; respondent ordered to pay specified arrears and ongoing child support; income imputed to respondent; GoFundMe excluded from claimant's Guideline income; no retroactive award in favour of respondent for the July 1, 2024–September 1, 2025 period.
Legal Topics
Child Support Guidelines, Imputation of Income, Retroactive Child Support, Section 7 Expenses, Disclosure Obligations, Review/variation of Support Order, Costs
Source Language
English
Family Law Child Support Income Imputation Child Support Enforcement Child Support Guidelines Imputation of Income Retroactive Child Support Section 7 Expenses +3 more

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Parties

A.C.S. also known as A.C.M.

Claimant

C.J.S.

Respondent

Procedural Posture

Family Law Child Support Review and Variation / Decision on Review Applications (reasons for Judgment)

Legal Issues

  1. 1 What are the parties' Guideline incomes?
  2. 2 Whether to impute income to the respondent under s.19 of the Guidelines
  3. 3 Whether GoFundMe donations constitute income for Guideline purposes

Ratio Decidendi

The court excluded the GoFundMe donations from the claimant's Guideline income and found the claimant's Guideline income commencing October 1, 2025 to be CAD 32,552 (employment insurance). The court imputed annual income of CAD 175,000 to the respondent (CAD 100,000 employment income and CAD 75,000 dividends) because of inadequate disclosure, inconsistent lifestyle with reported income and evidence of income manipulation; applied the Guidelines and relevant authorities to compute ongoing support of CAD 2,821 per month from October 1, 2025. The review effective date is June 19, 2024; the court declined to order retroactive support payable by the claimant to the respondent for July 1, 2024...

Court Disposition

Applications allowed in part; respondent ordered to pay specified arrears and ongoing child support; income imputed to respondent; GoFundMe excluded from claimant's Guideline income; no retroactive award in favour of respondent for the July 1, 2024–September 1, 2025 period.

Orders

  • Respondent to pay claimant CAD 12,520 for child support arrears no later than March 31, 2026.
  • Respondent to pay claimant child support of CAD 2,821 per month, retroactive to October 1, 2025.