In Kowalewich v. Kowalewich, 2001 BCCA 450, the court discussed the use of pre-tax corporate income when calculating income for support purposes. It stated at paragraph 54: 54 The Guidelines allow a court to include all of the pre-tax income of a corporation for the most recent taxation year in a spouse’s annual income for Guideline purposes. They do not require it. I am not persuaded they make the inclusion of all pre-tax income the default position.
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