The applicant mother sought an order requiring the respondent father to disclose unredacted U.S. income tax returns for 2017 and 2018, including his current wife's income information.
The father opposed disclosure, citing his wife's privacy interests.
The court balanced the privacy interests of the third-party spouse against the mother's need for accurate income information to calculate child support, particularly regarding tax rate differentials under the Child Support Guidelines.
The court found that disclosure of the wife's income was necessary to accurately determine the father's effective tax rate for gross-up calculations, as the father and wife filed joint returns with a blended tax rate.
