What is the impact of past and future income loss on future income growth?

Both past and future income loss is properly considered on the basis of loss of earning capacity: Ibbitson v. Cooper, 2012 BCCA 249, at para. 19.

The burden of proof for actual past events is a balance of probabilities. However, the assessment of loss for both past and future earning capacity also involve the consideration of hypothetical events. The plaintiff is not required to prove these hypothetical events on a balance of probabilities; rather, hypothetical events are given weight according to their relative likelihood. The future or hypothetical possibility will be taken into consideration as long as it is a real and substantial possibility and not mere speculation: Athey, at para. 27; Morlan v. Barrett, 2012 BCCA 66, at para. 38.

An award for loss of earning capacity, whether past or future, requires an assessment that considers the overall fairness and reasonableness of the award, taking into account all positive and negative contingencies. It is not a calculation according to a mathematical formula: Schenker v. Scott, 2014 BCCA 203, at paras. 50, 53.