What is the test for self-sufficiency in spousal support calculations?

Paraphrasing our Court of Appeal in Fisher v. Fisher (2008), 88 O.R. (3d) at para. 52 to 55 , self-sufficiency is a relative concept. It is not achieved simply because a former spouse can meet basic expenses. A determination of self-sufficiency requires consideration of the parties’ present and potential income, their standard of living while married, the efficacy of any suggested steps to increase a party’s means, the parties’ likely post-separation circumstances including the impact of equalization and the duration of cohabitation. Self-sufficiency is often more attainable in short term marriages, particularly ones without children, where the lower income spouse has not become entrenched in a particular lifestyle, or compromised career aspirations. In such situations, the lower income spouse is expected to have the tools to become financially independent or to adjust his or her standard of living. In contrast, in most long term marriages, particularly in traditional long term ones, the parties’ merger of economic lifestyles creates a joint standard of living that the lower income spouse cannot hope to replicate, but upon which he or she has become dependent. In such circumstances, the spousal support analysis typically will not give priority to self-sufficiency because it is an objective that simply cannot be attained. (para. 53-55)