Does a change in income constitute a change of circumstances?

I interpret this provision to mean that any change in a parent’s income whether upward or downward may be a change of circumstances. As a result J.D.G. v. J.A.B. is useful in analyzing the issue around income changes and whether they constitute a “change of circumstances” if they are temporary or contrived. In that case, although there were decreases in income, the factual evidence led to a conclusion those changes did not constitute the necessary “change in circumstances”. The justice in J.D.G. v. J.A.B. utilized the analysis provided in Brown v. Brown, 2010 NBCA 5 to confirm that relief should not be given when there has been a decrease in income unless that decrease was significant and long-lasting, real and not chosen.