The factors to be considered in determining whether to award retroactive spousal support are similar to those that must be considered in determining whether to award retroactive child support: D.B.S. v. S.R.G., 2006 SCC 37; Kerr v. Baranow, 2011 SCC 10 at para. 207. They include: the reasons why support was not sought earlier; the conduct of the payor parent; the circumstances of the child; and any hardship the retroactive award may have upon the payor spouse.
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