Madam Justice Prowse quoted with approval the words of Madam Justice L’Heureux-Dubé in Moge v. Moge, 1992 CanLII 25 (SCC), [1992] 3 S.C.R. 813, 43 R.F.L. (3d) 345 at 389: The financial consequences of the end of a marriage extend beyond the simple loss of future earning power or losses directly related to the care of children. They will often encompass loss of seniority, missed promotions, and lack of access to fringe benefits, such as pensions, plans, life, disability, dental, and health insurance . . . As persons outside of the workforce cannot take advantage of job retraining and the upgrading of skills provided by employers, one serious economic consequence of remaining out of the workforce is that the value of education and job training often decreases with each year in comparison to those who remain active in the workforce and may even become redundant after several years of non-use. All of these factors contribute to the inability of a person not in the labour force to develop economic security for retirement in his or her later years.
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