In
Licata v Shure, the Court of Appeal for Onario
clarified the issue of material change in circumstances as it
relates to child support orders made on consent.
The parties were married for twenty years, separating in 2014.
In 2015, they entered into an agreement which served as the
foundation for a 2017 consent order. The consent order determined
issues of spousal support, child support, sharing of special and
extraordinary expenses for the children, division of property, and
parenting arrangements. It also included a formula allowing the
parties to share special and extraordinary expenses for the
children, such as their “post-secondary education and related
expenses” and tutoring fees.