The major difficulty in determining an income expressed in Canadian funds is in fixing the correct approach to conversion because there can be wide and rapid fluctuations in currency exchange rates. In Horton v. Horton, [1999] O.J. No. 4855 (Q.L.) (S.C.J.), both parties presented different exchange rates but the trial judge opted for the average of the over-the-counter rate and the rate reported at the date of the hearing.
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