Incomplete financial disclosure can affect income imputation, property division & claimed deductions. Two 2026 Ontario Court of Appeal decisions show why evidence and reliable records matter.
By Vaneet Sangha, Co-founder, OMNI LAW GROUP
In This Guide
What Chamseddine v. Ghani says about corporate ownership, income and property; how Sohal v. Bhatthal addresses imputed income and a pre-marriage property deduction; and practical disclosure points for Orangeville and Dufferin County families.
Quick Facts
Chamseddine v. Ghani, 2026 ONCA 697: appeal dismissed.
Sohal v. Bhatthal, 2026 ONCA 688: appeal dismissed.
Both decisions address financial evidence in family-law disputes.
The facts in each case are specific. They do not establish that every financial discrepancy is deliberate concealment.
Why does financial disclosure matter in an Orangeville divorce?
Financial disclosure gives the court evidence to assess income, assets and claimed debts or deductions. When records are incomplete, the resulting uncertainty can affect the court’s findings.
That is the practical thread connecting these two 2026 decisions. In Chamseddine, the Court of Appeal upheld findings about beneficial ownership, income imputation and unequal division of net family property. In Sohal, the Court upheld an income imputation and refusal of a claimed date-of-marriage deduction.
The decisions do not say that a disputed figure alone proves someone hid income or assets. They show that a party’s position must be supported by the available evidence. In an Orangeville divorce involving a business, property or support, accurate records can be central to the financial analysis.
How did Chamseddine v. Ghani address business ownership & income?
In Chamseddine v. Ghani, 2026 ONCA 697, the husband ran successive corporations: C.D., then C.W., then Aspen. His brother was the sole registered shareholder. The trial judge found that the husband was always the beneficial owner.
The Court of Appeal dismissed the husband’s appeal. The beneficial-ownership finding supported an unequal division of net family property under section 5(6) of Ontario’s Family Law Act. The trial judge estimated reckless depletion at $120,000, awarded half of that amount to the wife, and ordered a total of $65,710 payable on account of property.
The court also upheld imputed income of $250,000 for 2023 and $200,000 per year thereafter. The calculation drew on the husband’s own sworn financial statement, including personal expenses, housing and transportation. The amount was grossed up for tax and adjusted for the loss of the Home Depot contract.
The Court of Appeal noted that, once an evidentiary foundation is established under section 19(1) of the Federal Child Support Guidelines, the other party must proactively disclose. That makes complete, responsive financial disclosure important when the evidence raises questions about income.
What happened to the claimed mortgage & the matrimonial home?
The husband claimed a vendor take-back mortgage on the matrimonial home. The only document was a one-page 2021 mortgage commitment. It was signed by parties with no legal authority to encumber the property.
The Court of Appeal upheld the conclusion that there was no vendor take-back mortgage. The home was ordered sold.
For families in Dufferin County, the practical point is narrow but important: a claimed debt or interest in property needs reliable supporting documents. A record that does not establish the claimed arrangement may not support the position advanced in court.
Why did Sohal v. Bhatthal uphold imputed income?
In Sohal v. Bhatthal, 2026 ONCA 688, the Court of Appeal dismissed an appeal and upheld annual imputed income of $400,000 for intentional underemployment.
The father had left a well-paying salaried position and joined his extremely successful father’s business. The trial judge found that the father had simply not re-entered the workforce. The Court of Appeal upheld the imputation.
This result is tied to the facts recorded in the case. It is not an automatic income figure for another family or another business. The decision illustrates that employment history and the evidence about a party’s work circumstances may matter when income is disputed.
For a Dufferin County family assessing support, the case also underscores the value of clear records and complete financial disclosure. A position about income should be considered alongside the evidence supporting it.
Why was the Upper Gage property deduction refused?
The father sought a $150,000 date-of-marriage deduction for the Upper Gage property. The property had been sold one month before the marriage and had never been disclosed. The father failed to meet his onus, in part because of a lack of documentation.
The Court of Appeal upheld the refusal of the deduction. The case shows how documentation can matter when a party claims a pre-marriage property deduction. A claim needs evidence that supports it; an assertion alone may not be enough.
In Chamseddine and Sohal, the financial issues differed. One concerned beneficial ownership, income and depletion of property. The other concerned imputed income and a claimed property deduction. In both, the result depended on the evidence and the trial judge’s findings.
What should Orangeville & Dufferin County families take from these cases?
For a family dealing with divorce, separation or financial disclosure in Orangeville, these decisions support three practical points:
Keep financial information complete. Income, personal expenses, business interests and property positions may all be relevant to the issues in dispute.
Support claims with documents. Sohal shows the difficulty of a deduction claim where documentation was lacking. Chamseddine shows the importance of evidence about ownership and a claimed mortgage.
Avoid assumptions about intent. A disagreement or inconsistency is not, by itself, a finding of deliberate concealment. Each case turns on its own evidence.
The 2025 Federal Child Support Guidelines tables took effect on October 1, 2025, and remain in force during 2026. Use the official 2025 child support tables for table information. The imputed-income findings in these cases are specific to their records.
Where can Orangeville & Peel families get help?
OMNI LAW GROUP’s Orangeville office is located at:
162 Broadway, Suite 8
Orangeville, ON L9W 1K3
905-497-7200
The Orangeville Courthouse is at 10 Louisa Street. Peel Region court matters are processed at the A. Grenville & William Davis Courthouse, 7755 Hurontario Street, Brampton. Plan time for courthouse entry and security lines.
There is no current Brampton office. Peel matters are served from the Orangeville base. For family-law support, see our Family Lawyer in Brampton service page. These two Court of Appeal decisions concern family-law financial issues, not criminal charges. For a separate criminal-law matter, see our Criminal Defence Lawyer in Orangeville service page.
Business Hours: Monday to Friday, 9:00 AM to 5:00 PM.
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This article is general information only, not legal advice. It does not create a solicitor-client relationship.
Local Legal FAQ
Can a court impute income in an Ontario divorce if financial disclosure is incomplete?
In Chamseddine v. Ghani, the Court of Appeal upheld imputed income of $250,000 for 2023 and $200,000 per year thereafter. The calculation used evidence from the husband’s sworn financial statement, including personal expenses, housing and transportation, with adjustments for tax and the loss of the Home Depot contract. The court also stated that, once an evidentiary foundation is established under section 19(1) of the Federal Child Support Guidelines, the other party must proactively disclose. The decision turns on its evidence; it does not set an income figure for other cases.
What did Chamseddine v. Ghani decide about business ownership?
The husband operated successive corporations, C.D., C.W. and Aspen, while his brother was the sole registered shareholder. The trial judge found that the husband was always the beneficial owner. The Court of Appeal dismissed the appeal and upheld the use of that finding in the unequal division of net family property under section 5(6) of the Family Law Act. The court also upheld findings about imputed income and the claimed vendor take-back mortgage. Those conclusions arose from the evidence in that case and do not establish ownership in another family’s business dispute.
Why was the Upper Gage property deduction refused in Sohal v. Bhatthal?
The father sought a $150,000 date-of-marriage deduction for the Upper Gage property. The property had been sold one month before the marriage and had never been disclosed. The father failed to meet his onus, in part because of a lack of documentation. The Court of Appeal dismissed the appeal and upheld refusal of the deduction. The case illustrates the role of evidence in a property deduction claim. It does not determine how a different property claim will be decided; the facts and documentation in that matter would need to be assessed.
ABOUT THE AUTHOR
Vaneet Sangha is Co-founder of OMNI LAW GROUP and a member of the Law Society of Ontario.
For an initial consultation at 162 Broadway, Suite 8, Orangeville, ON L9W 1K3, call 905-497-7200.
We handle matters at the Brampton Davis Courthouse.
We focus on the intersection of Criminal Defence & Family Law.