What is the test for reduction or cancellation of income tax arrears?

In Kular v. Kular, 2018 BCSC 1715 at paras 19-21, Justice Choi summarized the governing principles for reduction or cancellation of arrears: a) The payor bears a heavy onus to establish that “it would be grossly unfair not to reduce or cancel the arrears”; b) The test for cancellation of arrears is onerous and not easy to meet: “gross unfairness” is a high bar; c) Accordingly, cases in which arrears been cancelled are rare (Luney v. Luney, 2007 BCCA 567 at para 43); d) The evidence must be reliable, accurate, and complete; e) The applicant cannot rely on hearsay evidence; and f) Financial disclosure and obligation to earn capacity inform whether there has been a change in circumstances: has the applicant proven a significant and long-lasting change in circumstances due to a reduction in income?