[138] The Court of Appeal in Virc v. Blair, 2014 ONCA 392, [2014] O.J. No. 2301, at para. 58, stated that “[i]n the face of a deliberate material misrepresentation, the onus is not appropriately placed on the recipient spouse. Rather, the party disclosing financial information bears the onus of establishing that the “recipient” spouse was aware of the non-disclosure or falsehood.
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