V Legislated Rules to Generate Final Child Support Amounts

A. Introduction

As outlined in Chapter II, accompanying rules as set out in legislation or administrative agency policy are relevant to the determination of child support. The purpose of this chapter is to describe how the ten jurisdictions apply the rules pertaining to:

How income is defined and which deductions (taxes, self-support reserves, dependent children) are considered to calculate the amount of income available for the determination of child support.
Parenting time/custody type – how time spent by the child with the parents is incorporated into the formula.
How dependent children from different relationships are addressed within the models – such as second families, stepfamily and persons acting in place of a parent.
Departures from the basic child support amount – such as special expenses, childcare, medical, school or extracurricular expenses, as well as expenses for special needs.
Approaches to vary and/or update child support amounts – such as what “triggers” a variation, frequency of updating of child support orders, and what circumstances may constitute “undue hardship”.
Other circumstances relevant to the determination of child support – such as the age of the child, minimum or maximum amount orders, the treatment of high or low earners, and any capping or the use of marginal capping of child support amounts.

Tables 6, 7, 8, 9, 10, 11 and 12 provide details on each of the rules outlined above (the presence or absence of a factor, a brief description, and how it is applied) for each jurisdiction. With the exception of Table 6, all tables can be found at the end of this chapter. As well, the jurisdictional summaries in Volume II provide further details.

B. How Income is Defined and Used in the Formula Calculations.

A key piece of information that is required when using a child support formula is the incomes of the relevant parties. This section describes the “starting”99 income that the jurisdictions require, and the various elements used to convert that income into an income available for the determination of child support. It describes how income is defined in legislation, identifies what types of income are considered, and provides a summary of the types of allowable deductions from income, such as self-support reserves and amounts for other dependent children.

This section also identifies whether jurisdictions allow for imputing of income and how the income information is collected – such as income details that are provided by the taxation authority in the jurisdiction or provided by the parents.

Table 7 displays these factors by jurisdiction.

1. Income defined

All jurisdictions define the starting income for use in the calculations as a person’s gross income as reported to tax authorities. This includes wages (salaries, commissions, bonuses, and other income), income earned as an independent contractor, and all other taxable income that does not come from earnings such as dividends, severance pay, pensions, workers compensation, and spousal support/alimony received. Jurisdictions include various other types of income received based on their particular circumstances, but these are exceptions rather than the rule.

2. Taxes

Only three jurisdictions – Vermont, Illinois and Sweden – include calculations that deduct applicable taxes from their starting gross incomes to determine the “net of tax” income. To determine the “net of tax income”, all use standard tax deductions that are relevant in their jurisdiction based on the level of income of the parents. Sweden uses the same tax parameters and calculations for both parents to convert gross to net income. In Vermont and Illinois, the conversions from gross to net differ depending on whether you are the paying or receiving parent. For example, in the 2017 Illinois “Gross to Net Income Conversion Table Using Standardized Tax Amounts”, a non-custodial person earning $5,200/month converts to $3,949/month net income. For a custodial parent with one child, for the same gross income, the conversion to net is $4,041 per month. Custodial parents have lower net incomes because they have additional allowances deducted from their income to reflect the costs for the child.100

In both Vermont and Illinois, the responsible administrative agencies provide their respective Adjusted Gross to After Tax Income Conversion Tables to assist parents and family law officials in completing the conversion calculations. These tables display monthly gross incomes, broken down by the income levels of the paying and receiving parents and the number of children. Sweden includes the tax rate as a percentage of gross income directly in its online calculator.

The remaining jurisdictions use “gross” or “taxable” income as their starting income in the first step in the formula calculations.

3. Self-support reserve101

The self-support reserve is an amount designed to allow the parents to take care of their basic needs. Six jurisdictions102 incorporate self-support reserves into their formula calculations. However, this concept is reflected in the formula differently, depending on the jurisdiction.

In four jurisdictions (Australia, New Zealand, Delaware and France), a self-support reserve amount is a mandatory deduction that is included in the calculation of income available for child support purposes. This calculation is made after the gross income amount is determined.

In Vermont and Illinois, the self-support reserve is imbedded in the gross to net standard calculations as a “personal exemption”.

In Sweden, parents may deduct an amount for actual “living expenses”. Although this deduction could be considered akin to the concept of a self-support reserve, unlike in the other jurisdictions, the amount for living expenses that can be deducted can exceed the expenses for what one would consider “expenses that represent an amount for basic needs”.

All the jurisdictions that include a self-support reserve in their models are based on an income shares approach. Consequently, the self-support reserve is applied to the income calculations for both parents.

The remaining four jurisdictions (Sweden, Norway, Wisconsin and the United Kingdom) do not have a self-support reserve amount deducted as part of the calculation to determine income available for child support purposes.

4. Dependent children103

The consideration of other dependent children in the calculation of child support has been widely discussed over the years.104 Whether to include adjustments in the calculations for other dependent children requires a policy decision from the jurisdiction on whether all children for whom the parents are legally responsible should be treated equally when allocating financial resources. Those in support of equal financial treatment for all children, regardless of the order of claim, support inclusion of a calculation in the formula to reflect existing or prior financial responsibilities. Those who do not support this approach, argue that allowing for a deduction in the formula calculations rewards parents for having multiple families.105 The policy decision that a jurisdiction adopts on this issue will be reflected in their child support formula.

In six jurisdictions106, the calculation of income available for child support purposes includes, if applicable, a deduction from the income for an amount for dependent children who are not part of the current child support determination. While the jurisdictions take different approaches to defining dependent children, all approaches generally include children from a previous relationship, adopted children, and/or new children as a result of a new relationship. The jurisdictions have different ways of incorporating this deduction. Some jurisdictions will allow the deduction of existing child support obligations. Others will also allow the deduction when proof of parenthood for any child they are claiming as a dependent child, is provided. Still other jurisdictions separate children from a new relationship from those children from a previous relationship and require different calculations.

In cases where calculations are taken into account for dependents that are step or new children, most jurisdictions with models based on an income shares approach determine the applicable amount to be deducted by using the amounts obtained in their relevant tables pertaining to expenditures on children. The parent claiming the dependent child deduction will consult the table to determine the applicable amount, and then will deduct that amount from their gross or net income.

In Delaware107, if either parent is supporting a dependent child, then Net Income After Self-Support is reduced by 30%.

Australia, New Zealand and Illinois have defined concepts of “multi-case”, “multi-group” or “multi-family” allowances respectively for parents to determine the appropriate amounts of deductions from income for children from previous relationships.

These three jurisdictions use an income shares model. Therefore, the adjustment for dependent children or for multiple children from previous relationships is available to both parents and can be deducted from their incomes, when applicable.

Two of the three percentages of income models (the United Kingdom and Wisconsin) also have an adjustment for dependent children. In the case of Wisconsin, it has a separate formula called the “serial-family parent” to adjust for other dependent children when calculating child support. Instructions are provided on how to calculate child support for each dependent child prior to determining the child support amount for the child that is the subject of the current child support calculation.108 It should be noted that provisions in the Wisconsin model follow the birth order of the children (the first-born child has access to all of the paying parent’s income, while the second born has a reduced income available following the deduction of the first child’s amount from the paying parent’s income). Similarly, for a third or fourth child, the paying parent’s income available for child support is less after each additional child.

For the United Kingdom, relevant other children (dependent children) are accounted for by selecting the appropriate percentage from a table that shows the number of relevant other children (from one to three or more), by the number of children subject of the current case (from one to three or more). The percentages to multiply by the income of the paying parent are provided in each cell of the table. The result is the amount of the deduction from the paying parent’s income.

5. Other allowable deductions

In a few jurisdictions, various other deductions may be included in the calculation of income available for child support purposes. In the United Kingdom, for example, the calculations allow for deductions for pension contributions. In Delaware, pension contributions, amounts for medical and disability insurance premiums, union dues, court ordered spousal support, and other child support amounts paid are also allowable deductions. In Sweden, the model allows for the deduction of housing costs for both parents when calculating their available income for child support.

6. Imputation of Income

All jurisdictions include provisions for imputing income. The most frequently cited reasons when it is justifiable to impute income are when a parent does not provide the information in a timely fashion, has never filed a tax return, or is purposely unemployed or underemployed.

All jurisdictions employ various methods to impute income. The most common methods are based on past employment, if available, or by using some modification of the national average annual earnings to assign income for the purposes of the child support determination.

7. Access to income data for the purposes of calculating child support

As mentioned in Chapter III, several jurisdictions (the United Kingdom, Australia, New Zealand and Norway) have direct access to income information from their respective taxation authorities. This capability allows the administrative agency responsible for determining child support amounts to readily have access to timely, accurate income information as well as any benefits that either parent may be receiving. In Sweden, tax records are public, so authorities can easily access a parent’s records if necessary.

C. Approaches Used to Address Various Parenting/Custody Arrangements

All ten jurisdictions incorporate provisions in their models to recognize the time either parent spends with their children. All models include calculations that recognize:

Split custody situations where each parent has at least one child for a significant period of time.
An amount of time that doesn’t reach the minimum threshold to qualify for a reduction in the child support amount.
An amount of time above this minimum that qualifies for an adjustment to the child support amount to recognize the additional time spent with the other parent.

Time spent with a child is most often calculated as the number of overnights or an amount of time that is an equivalent to overnight time.109

Table 8 provides information on how each jurisdiction incorporates parenting arrangements into their model.

1. Split custody

All jurisdictions have rules in their legislation that define split custody and how the child support calculations are to be completed in split custody cases. In all jurisdictions, split custody is defined as having a parenting arrangement where the two parents have two or more children and each parent has one of the children living with them for greater than a period of shared time, which is defined by a threshold.110

In jurisdictions where the model is based on an income shares approach (including the Delaware Melson Model), both parents complete the formula calculations based on the number of children who are in their care. Essentially, each parent completes the formula calculations as if they had sole custody for the child in their care. Once the amounts are determined for each parent, the parent with the higher amount will pay the difference between the two amounts to the other parent.

Although Wisconsin uses a fixed percentage of income model, the income of both parents is used in the calculation of child support in cases of split custody. In these cases, the expenditure percent that is used to generate the child support amount111 is divided by the number of children, regardless of where they will be residing. This results in a per child percent of the child support amount. Each parent then multiplies their appropriate percentage (based on the number of children in their care) by their income. The amount for each parent is determined, and the two amounts are subtracted, with the parent with the higher amount paying the difference between the two amounts to the other parent.

2. Shared custody or parenting continuum of care

Although a jurisdiction may use the term “shared custody”, what is being referred to is really a continuum of care that results in the time the child spends with the other parent being factored into the formula calculations. Jurisdictions all vary in the terminology they use in their models to describe their parenting arrangements.

All jurisdictions have clear rules and very complex calculations112 that result in adjustments to the child support amounts if the child spends time with the other parent that exceeds a defined overnight threshold. As well, all jurisdictions calculate “time” as being overnight time, with two jurisdictions (Wisconsin and Sweden) also counting time with the child in blocks of continuous time or long periods during the day.113

Jurisdictions have taken different approaches with respect to the following parameters.

Minimum threshold

Each jurisdiction has developed a minimum threshold of parenting time below which the child support amount is not adjusted. In other words, if the paying parent is spending an amount of time with the child below this threshold, the child support amount is not reduced. The range for each jurisdiction is provided in Table 6 below. It varies from a low of 6.5% of the time per year in Norway, to a high of 40% in Illinois.

Table 6: Minimum Threshold of Parenting Time, by Jurisdiction
Jurisdiction	Lowest Threshold of Parenting Time
Norway	6.5 % per year / 2 nights per month
Australia, United Kingdom	14% per year / 52 nights per year
Sweden	20% per month / 5 consecutive days or 6 days per month
Delaware	22% per year / 80 nights per year
Vermont, Wisconsin	25% per year / 92 nights per year
France	25% per month
New Zealand	28% per year / 103 nights per year
Illinois	40%

In cases where the child is spending time with one of the parents above the minimum threshold, adjustments to the child support amount are made to recognize the parenting time arrangement. Each jurisdiction has their own unique approach to how their model accommodates these adjustments for parenting time. A review of the jurisdictions’ models shows that with the exception of Delaware, there are three noteworthy groupings. They are as follows:

Models that increase expenditure amounts and then divide costs

In Illinois, Vermont and Wisconsin, their respective models recognize that the expenditures to care for the child increase to cover the increased cost of the shared parenting arrangement. The approach is to multiply the expenditures on children by a factor of 1.5 to cover the increased costs. For example, in Illinois and Vermont, the calculations are as follows:

The parents’ combined incomes are used to look up the appropriate child expenditure amount from their Table of Child Support Amounts.
That amount is multiplied by 1.5 to obtain the Shared Child Support Amount.
Then, the Shared Child Support Amount is apportioned between the parents to determine their respective share (for ease of understanding, this amount is called the Parents’ Respective Shared Child Support Amount).
The parent with the higher Parents’ Respective Shared Child Support Amount must then multiply this amount by the percent of time the child spends with them. This amount is called a Percentage Time Amount.
Then, the Percentage Time Amount is subtracted from their Parents’ Respective Shared Child Support Amount to obtain a final child support award.
In Wisconsin, because it is a percentage of income model, the calculations are done differently. Each parent multiplies their income by the percentage standard amount that represents the cost of the child. The two resulting amounts are multiplied by 1.5. Each of the parent’s new amounts is then multiplied by the other parent’s actual percentage of parenting time. The two results are subtracted from one another and the parent with the positive amount is the paying parent.
Models that allow for a percentage deduction or “credit” that reduces the child support amount

In the United Kingdom, Norway, Sweden and France, the models allow for a credit or a deduction to the child support amount, for time spent with the child.

In the United Kingdom, the model allows for a reduction to the child support amount based on bands of parenting time: i.e. if the child spends between 52-103 nights with the other parent, there is a 14% reduction in the child support amount, 104-155 nights, a 28% reduction and if between 156-174 nights, a 42% reduction.
In Sweden, if the minimum threshold is met, the child support amount is reduced by 1/40 of that amount for each night of parenting time.
In Norway, a lookup table is provided that identifies the costs associated with the different levels of care and ages of the children. For each child, these costs are subtracted from the child support amount.
In France, the model incorporates the categories of parenting time (reduced – less than 25%; classic – over 25%; and alternating – child live alternately in the home of each parent114) directly into their percentages of income categories, by number of children. If the parenting time arrangement was classified as “classic” for example, the percentage of income that is applied to the income of the paying parent to determine the child support amount is lower than the percentage that would be applied if they had a “reduced” parenting time arrangement.
Models that incorporate a sliding scale into their calculations

In Australia and New Zealand, the progression of time spent with the children from 0 to 100% is measured in overnights and calculated as a percentage. Each parent’s actual percentage is then used to determine the relevant amount in their respective lookup table (percentage of care tables). Each parent is assigned a “care percentage”. Each parent’s care percentage amount is then subtracted from his or her income share percentage amount. The parent with the positive result is the paying parent115 (see Table 6). The policy rationale for this approach is that the costs associated with time spent with the child reduces the amount of income available for child support; hence the parents care percentage amount is subtracted from their income share percentage.

Delaware Model

Finally, in the Delaware model, if the child resides with one of the parents for more than 45% of the time, the child is counted as 0.5 or “½ of a child” for the purposes of the formula calculations.

For circumstances where there is less than 45% time spent but more than the minimum threshold of 22%, then both the amount that represents the Basic Needs of the Child plus the Standard of Living Adjustment Amount are adjusted to reflect the costs of the parenting arrangements.116

D. Approaches That Consider Other Families/Dependents

1. Dependents

As outlined in Chapter III, almost all jurisdictions have in their legislation or administrative rules consideration of the financial obligations that either parent may have with respect to:

Other biological children born in a new or subsequent relationship(s).
Stepchildren or children who live with either parent but that are not their biological children.
Children from a past relationship that they are either financially supporting by way of a child support award or have split custody with one or more children in their care from a past relationship.

The underlying policy objective achieved by deducting an amount for dependent children as a preliminary step in the calculation of income available for children is that children from previous relationships and/or current dependent children must be financially taken care of first, before the parents can share any excess available income with subsequent children.

Table 9 identifies which jurisdictions allow for the consideration of other dependent children in their models. It is displayed in two columns as dependent children (which means children from a present relationship) and “more than one dependent from a previous relationship” (which means children from previous relationships with or without a child support order).

In six jurisdictions117, financial obligations emanating from other families/dependents are taken into account before the income available for child support is determined for the child that is the subject of the child support calculation. In these cases, the amount determined for eligible dependents is subtracted from the income of the parent claiming the dependents (as outlined in the section in this chapter pertaining to the income calculations). The exception is Delaware: it does not calculate an amount, but rather it reduces the income by a set percentage (30%) regardless of the number of dependent children.

Three jurisdictions have multi-family (Illinois), multi-case (Australia), or multi-group (New Zealand) rules embedded in their models to ensure children from previous relationships are accounted for. The calculations in these models ensure that all the children who are the responsibility of one parent, are treated equally with regards to how the calculations are completed to determine the income available for child support for any subsequent children.

Wisconsin, because it is percentage of income model, has a separate formula (called a Serial-family Parent)118 to deal with children from both a new and previous relationship. As noted earlier, the calculations to determine the deduction amount for dependent children follows the birth order of the children. The first-born child has access to all of the paying parent’s income, while the second born has a reduced income available following the deduction of the first child’s amount from the paying parent’s income. Similarly, for a third or fourth child, the paying parent’s income available for child support is less after each additional child.

Finally, Norway is the only jurisdiction that includes a calculation that takes into account the financial responsibility of having dependent children as part of their “ability to pay” assessment. This is completed as the last step in their formula calculations. Once the final child support amount has been determined, a series of allowable deductions such as amounts for taxes, housing costs, a personal amount and an amount for other dependent children119 is deducted from the gross income of the paying parent to determine if the paying parent has the financial ability to pay his child support obligations.

Sweden and France do not have specific provisions in their models that account for the financial responsibilities pertaining to other dependent children. However, their formula calculations do allow for the financial implications of having dependent children.

2. Spousal support

In 2018, the US federal government changed the tax treatment of spousal support 120 so that it is no longer deductible from the income of the paying parent nor is it included as income for the receiving parent in the calculation of income available for child support. All four states have either changed, or are in the process of changing, their respective legislation to reflect the requirements set out in the federal legislation. Three of the four (Vermont, Delaware and Illinois) allow a deduction for spousal support from income and include it as income for the receiving parent.

E. Special Expenses

Included in this review is an examination of how special expenses such as tuition, day care, special needs, and childcare are addressed in the models. Table 12 sets out the various types of expenses and how they are treated in the calculations, by jurisdiction.

In Australia121, New Zealand and the United Kingdom, special expenses do not form part of the formula calculations. However, a request by either parent for special expenses to be added to the child support amount will be considered by their respective administrative agencies provided that they meet certain criteria. These criteria are included in a list of “grounds for administrative review” (New Zealand) or “reasons for departure” (Australia) or “special variation expenses” (United Kingdom). In order to consider any additional special expenses, the administrative body requires proof of the necessity for those expenses such as:

The costs to cover the child (or children's) needs.
The extra costs to either parent to care for or educate the child (or children) in the way that was expected by either parent.

Both Sweden and Norway allow for the costs of childcare to be included in the calculations of the costs of the child that are shared between the parents. While Sweden does not have rules regarding other types of special expenses, Norway does allow expenses for braces, glasses or lenses.

In France, the determination of child support does not recognize special expenses per se, such as extra medical costs or private tuition. However, as guidelines are discretionary for the courts in France, judges may consider these expenses as they deem appropriate.

In the jurisdictions whose models do allow for the inclusion of special expenses in their formula calculations (Illinois, Delaware, Wisconsin122 and Vermont), they all vary with respect to what they consider as an allowable special expense. However, these jurisdictions take a similar approach in two areas: medical expenses and childcare expenses.

1. Medical expenses

In the United States, children are covered with basic health insurance up to the age of 18. Nonetheless, the Family Support Act of 1988123 includes provisions that mandate all states to not only implement presumptive guidelines, but to also stipulate in their formulas and rules that parents provide their children with medical support in the form of private insurance.

Thus, in the three jurisdictions that require the income of both parents in the calculation of a child support amount (Delaware, Illinois and Vermont), all include deductions for private health insurance premiums paid on behalf of the children in their calculations of income for the purposes of child support. Should extra medical expenses be incurred, these expenses are added to the child support amount and become part of the “expenditures on children” to be divided between the parents in proportion to their incomes.

In Wisconsin, their model includes provisions for expenses for medical support based on the cost of local or nearby private health insurance plans. However, there is a test for the amount to be considered and it is deemed reasonable only if the cost of the plan does not exceed 10% of a parent’s monthly income.

2. Childcare expenses

Delaware, Illinois and Vermont all consider childcare expenses as part of their formula. The parent who incurs the costs must submit the expenses and they are then added to the “expenditures on children” amount, to generate a total amount of expenditures for the parents. This amount is then divided in proportion to the incomes of the parents.

With the exception of Wisconsin, each state requires proof regarding the necessity of the expenses and apportions them between the parents in proportion to their incomes.

F. Undue Hardship and Other Circumstances

Most jurisdictions have provisions or rules related to undue hardship and other circumstances that could be considered that might result in a variation or modification to the child support amount. These include:

Claims for undue hardship, such as ability to pay, huge debts or additional unforeseen costs.
Variation (or modification) of a child support amount due to a change in circumstances.
Updating of child support amounts, either automatically or due to updating of basic factors in the formula, such as the basic tables of expenditures, self-support amounts, standard of living adjustments or self-support reserves.

1. Claims for undue hardship

Across the ten jurisdictions, the concept of “undue hardship” is used in two different ways and reflected in the construction of the formula.

The first situation is where there is financial hardship, that is, where the paying parent has the required income to pay according to the calculations in the formula, but for other financial reasons (such as the significant costs due to a financial responsibility for other dependents, either adults or children), they assert that they cannot pay the required child support amount.

The second situation pertains to the financial ability of the paying parent to pay the child support amount. Essentially, this refers to the inability of the paying parent to pay the amount of child support given their low level of income.

These two situations are discussed further below.

Financial hardship

The majority of jurisdictions have provisions in their models to accommodate claims by either parent that they are unable to pay their child support amount or believe that the child support amount is not sufficient. In these situations, the claim must be proven, and the case is dealt with either administratively by an authorized administrative agency or by a court of law. Although there are some minor variations, in the majority of jurisdictions the reasons that are considered as reasonable grounds for a review include:

The parent has a duty to maintain another child (or children) or person;
The parent has necessary expenses to support themselves;
The parent has necessary expenses to support another child (or children) or person;
The parent’s contact costs are more than 5% of their adjusted taxable income;
The child support determination does not accurately take into account the income, earning capacity, property and financial resources of either parent or the child (or children);
The child support determination does not take into account that the parent has previously made payments, transfers or property settlements for the benefit of the child (or children);
The parent still has a financial interest in a property that the other parent is entitled to live in;
The child support assessment includes extra income earned from additional work to cover costs of re-establishment after separation; and
The parent would like the child support liability offset against child support owed to the parent.
Inability to pay

All jurisdictions have provisions in their models to accommodate circumstances where the paying parent is in a low-income situation or is unable to work due to being hospitalized or incarcerated. The mechanisms used by jurisdictions to ensure a balance between the ability to pay of the paying parent and the goal of child support guidelines (to ensure that parents exercise financial responsibilities towards their children), are consistent across all jurisdictions. In all jurisdictions there are provisions for:

A minimum income level threshold before the child support guidelines apply.
Established levels of expenditures for the child that reflect the income level of the paying parent – as the income level of the parent increases, so do the relevant expenditures for the child (to a maximum level for most jurisdictions).
Provisions for zero award levels if the individual is incarcerated or is unable to work due to reasons such as hospitalization.
Deviations to the child support amount if applicable grounds are met.

In addition to these provisions, four jurisdictions incorporate additional safeguards into their guidelines’ calculations to ensure that the paying parent has the financial capacity to meet their child support obligations.

Norway and Delaware have included an “ability to pay” test. This test applies to paying parents who have passed the income threshold and are deemed to have sufficient income to pay child support but, due to their own financial situation, may not be capable of paying their child support obligation.

In Norway, after the child support amount has been calculated, a final “ability to pay” calculation is completed. Starting with the paying parent’s gross income, a number of deductions are made such as amounts for the social security tax, federal tax deductions, deductions for their own maintenance, housing expenses, and maintenance for their other dependents living with them in their household. The resulting “net” income (after these deductions) must not exceed the child support amount. If this occurs, the resulting “net” income becomes the final child support amount.

Similarly, in Delaware, the last step in their formula involves a calculation to ensure that the paying parent is left with a sufficient disposable income after taking into consideration their child support award. Called a Self-protection Amount”, the calculated child support amount must not be greater than 45% of the paying parent’s income available for child support. Following this component of the calculation, the paying parent pays the lesser of the two amounts in child support.

Vermont also includes a calculation that is completed as a last step in the determination of the child support amount. A “self-support” reserve amount124 is subtracted from the paying parent’s monthly after tax income to derive an amount called Income Available for Support. This amount is then compared to the final child support amount, and the paying parent will be required to pay the lesser of the two amounts.

Finally, in Sweden, if the paying parent does not have the “ability to pay”, then no child support amount will be ordered.

2. Variations to child support amounts

In all the jurisdictions, the requirements to vary or modify an existing order are based on the requirement that there must be a real, substantial, and unanticipated change in circumstances, such as a significant change in income, disability, job loss, cost of visitation or health insurance, or a change in the custody arrangement. Some jurisdictions require an additional component that includes a threshold over which the recalculated amount must exceed the existing award by a certain percentage. For example, Vermont requires that the potential change to the child support amount must be more than 15% of the original order. In other jurisdictions, the threshold is related to the income level of the paying parent. For example, the United Kingdom requires that there be at least a 25% change in income level of the paying parent before a modification of an order will be considered.

In addition, some jurisdictions allow for variations under unique conditions. Both Australia and New Zealand will allow parents to seek a variation if the consumer price index changes dramatically. In these cases, however, the existing award must have been made at least 12 months earlier.

In the four American states, federal regulations125 require that all orders be reviewed every four years and changed, if applicable, regardless of whether there has been a substantial change in circumstances or not.

3. Updating of tables, expenditure data and child support amounts

Most jurisdictions automatically review their relevant tables or certain values (self-support amount, income levels in tables, etc.) on a periodic basis, and will update them if there is a material change in the numbers.

For example, Australia and New Zealand both update their child expenditure tables, as the income levels contained in them are based on multiples of Male Total Average Weekly Earnings (MTAWE). These amounts are updated annually when the new MTAWE values are published by their national statistical agency.

In other jurisdictions, such as in Vermont, Illinois and the United Kingdom, their administrative agency will conduct administrative reviews of their child support cases, either annually (United Kingdom) or over a longer period of time (Illinois) where the review must take place within three years of the original order being made. In Vermont, reviews of child support amounts will be completed as a result of legislated requirements such as missed child support payments.

Two jurisdictions, Norway and France, require that their orders all be indexed and updated annually to reflect the change in their respective consumer price index.

Finally, Sweden and Norway, as mentioned earlier, update their costs of child data annually based on the amounts provided by their statistical agencies on the average costs of basic items for children. This will often trigger changes to the child support amounts.

G. Summary of Other Factors

Other relevant factors, such as whether jurisdictions have provisions in place for the age of the child when the award is no longer applicable and minimum or maximum awards (or the treatment of high or low-income earners) are discussed below. A summary of these factors, and whether the jurisdictions have provisions to address these factors, are presented in Table 12.

1. Age of the child

In all jurisdictions, the payment of child support is not indefinite. In the four American states, along with Australia and New Zealand, child support will terminate when the child turns 18 years of age. However, each of them allows for the continuation of child support until the child turns 19 if they have not graduated. In these cases, the award terminates in whichever case comes first – graduation or their 19th birthday. The United Kingdom is similar to these six jurisdictions in that support ends at 16, but can continue to the child’s 20th birthday if they are still in full-time attendance at school/university.

The other three European jurisdictions (France, Norway and Sweden) are quite different in their approach to child support for older children. First, in all three jurisdictions, the child is a party to the proceedings after an age threshold is met. In Sweden and Norway, the threshold is when the child turns 18 and in France, it is when the child is able to cover their own needs. Furthermore, in all three jurisdictions, the child support may be paid directly to the child. Finally, in Sweden, child support will not continue after the child reaches the age of 21.

2. Minimum orders

All jurisdictions have provisions that allow for minimum orders and how they accommodate low-income earners varies. In the United Kingdom, Vermont and Norway, in certain circumstances, a zero award (or in the United Kingdom’s case, no order at all) is justified based on a low-income threshold that is established. In other jurisdictions, such as Australia, New Zealand, Illinois, Delaware and Wisconsin, a minimum order is made (ranging from $36 to $100 per month), regardless of the income circumstances of the paying parent. However, these orders can be suspended pending a change in circumstances of the paying parent.

France and Sweden do not have explicit rules about minimum orders. However, their guidelines are not presumptive and courts have the discretion to take into consideration the financial capacity of the paying parent in the determination of a child support amount.

3. Maximum order/high income earners

Most jurisdictions do not have a maximum amount of child support that can be calculated. However, some do have upper limits of income thresholds, after which their guidelines are no longer applicable. The rationale for the decision to determine an income amount at which the child support amount does not increase, is that at some point, the child support award is not reflective of the reasonable expenditures that would be spent on a child.

The upper limits of income levels are as follows:

In the United Kingdom, the limit is a weekly income of 7000£ ($11,725CDN).
For Vermont and Illinois, it is the highest income category of the parents’ combined net income from their Expenditure Tables, which translates into about $300,000 US per year.
In Wisconsin, there is a formula for high-income earners. The formula has two sets of percentages, one set for income levels up to a maximum income of $7000US / month and a second set of lower percentages for monthly income levels between $7000 per month to $12,500 per month. Above $12,500, the guidelines no longer apply.
In Australia and New Zealand, the last income band in their Table of Child Expenditures is set at 2.5 times the Male Total Average Weekly Earnings (MTAWE). Any incomes above this level must use the same child support expenditures amounts as at this highest income band. Therefore, if someone has an income of 3.5 times the MTAWE, their child support expenditures obtained from the table are the same as those with 2.5 times the MTAWE.
Delaware has two methods or calculations to ensure child support amounts do not exceed a threshold. The first is to use an “offset” for high incomes. For Net Income Available for Child Support over $15000 per month, the amount of income over that level is multiplied by 20% and subtracted from the income now available for the Standard of Living Adjustment. This reduces the “actual” available excess income to be shared with the child. The second method ensures that the final child support amounts are capped and do not exceed a percentage of income of over 45% of the paying parent’s Net Income Available for Child Support.
Norway imposes two “limits” that must be considered. These are: the paying parent shall not pay more than 5/6 (or 83.3%) of the Maintenance Cost of the child, nor shall he pay more than 25% of the receiving parent’s calculated gross income.
France and Sweden do not have any rules on maximum orders or high-income earners.

H. Summary

The construction of the child support models reviewed includes accompanying rules that set out how various elements are to be taken into account in the calculation of a child support amount. This chapter describes how the jurisdictions apply these rules and highlights areas in which they are similar and in areas in which they differ. The following are the main observations:

The determination of income that is available for child support is more complex than merely ascertaining whether the starting income for the calculation is net income or gross income.
Seven of the ten jurisdictions use gross income as the starting income for their child support calculations, with no deduction for taxes. Two jurisdictions (Vermont and Illinois) use net income as a starting income and provide tax conversion tables to assist parties in the calculations. The remaining jurisdiction, Sweden, applies the same percentage of income (31%) for its tax calculations.
Most jurisdictions include provisions in their models that allow for deductions of amounts for a self-support reserve amount and other dependent children, in the determination of income available for child support. Six jurisdictions126 include a self-support reserve amount that is deducted from gross income and six jurisdictions127 include deductions for other dependent children. Four jurisdictions (Australia, New Zealand, Vermont and Illinois) have provisions for both.
All jurisdictions incorporate provisions in their models to recognize the time either parent spends with their children. There is greater consistency in the way in which jurisdictions accommodate split custody situations in the formula calculations than how they accommodate shared parenting time arrangements. No jurisdiction allows for discretion on how to calculate child support amounts for parenting time. All jurisdictions have complex calculations that require online tools and worksheets to assist parties.
The majority of jurisdictions have provisions that allow for the recognition in the formula calculations, of other dependent children. The underlying policy objective achieved in the way in which the calculations are completed is that the financial needs of previous and current dependents take priority over the financial needs of subsequent children.
Most jurisdictions do not have specific provisions to allow for special or extraordinary expenses. If they are allowed, the types of expenses that are considered are for childcare and medical costs.
All models take into account the ability of the paying parent to pay their child support obligations. The financial hardship of low-income parents to pay child support is recognized through various mechanisms that are built into the formula construction. These mechanisms are common across all jurisdictions, and a balance is maintained between recognizing financial hardship and the responsibility each parent has for the economic wellbeing of their child.
The rationale for allowing either party to request a modification or variation to a child support award is common across all jurisdictions. Most require a percentage threshold to be met, either a change in the new amount of child support or a substantial change in the level of income, before they allow for a variation to the child support award. Again, common across all jurisdictions are other changes in circumstances, such as a change in parenting time or shared care, or the child reaches the age limit after which child support is no longer applicable.
Jurisdictions review on a regular basis the tools that are in place to assist parents, such as the relevant tax conversion tables, child expenditure tables, and amounts for self-support reserves. This review ensures that these tools reflect the currently available data.
All jurisdictions have provisions that recognize the limited ability to pay of low-income earners. The majority of jurisdictions include provisions in their models that allow for zero awards or minimum awards. Similarly, most jurisdictions have rules and calculations to ensure that child support amounts in cases of high-income earners do not exceed what would be reasonable expenditures on a child. Finally, some jurisdictions have upper limits of income thresholds after which their guidelines are no longer applicable.

Table 7: Determination of Income for Child Support Purposes128
Jurisdiction	How income is transformed from gross income into “child support income” for use in the formula					Imputation of income
Jurisdiction	Types of income included in “gross income”	Are taxes subtracted?	Is there a self- support reserve?	Are there allowable deductions or additions?	Terms of income available for child support to be used in formula	Imputation of income
United Kingdom	The starting point for the calculation is gross income (of the paying parent). It includes all types of income. Source: HM Revenue and Custom Agency provides income information automatically.	No	No	Yes, where applicable. Pension contributions may be deducted. Deductions are allowed for relevant other children (conditions apply). Deductions for special variation expenses.	Gross Weekly Income	Yes. If the paying parent does not provide sufficient income information, and if the information cannot be obtained from the paying parent’s tax records, then a default maintenance decision will be made.
Australia	The starting point for the calculation is gross income of both parents. It includes all types of income. It is called “Adjusted Taxable Income amount”. Generally, a parent's taxable income is the amount that is assessed by the Australia Tax Office (ATO) under the Income Tax Assessment Act for the relevant year of income. Both parent’s incomes are calculated in the same way.	No	Yes. A self-support amount is deducted from income and is based on the amount of the Male Total Average Weekly Earnings. (MTAWE).	Yes – if applicable. Relevant Dependent Child Amount. For a child with whom the parent has at least 35% care. Multi-case allowance. When a parent has more than one child support assessment.	Child Support Income	It is intended to cover circumstances, such as where a parent has never filed a tax return, or where the Registrar is unable to ascertain a person's tax file number. The Registrar may determine that the parent's adjusted taxable income is an amount that is at least two-thirds of the annualized MTAWE figure.
New Zealand	The starting point for the calculation is gross income of both parents. It includes all types of income. Called “Annual Adjusted Taxable Income”, it is calculated in accordance with section YA 1 of the Income Tax Act 2007. Both parents’ incomes are calculated the same. Source of information obtained: tax files at Inland Revenue Department (IRD).	No	Yes – It is called a “living allowance”, which is subtracted from both parents’ adjusted taxable incomes. The living allowance is calculated annually and is based on the social benefit a single person with one dependent child would receive in that year.	Yes – if applicable. Dependent Child Amount. For a child with whom the parent has at least 28% care. Multi-group allowance. When a parent has more than one child support assessment.	Child Support Income	IRD can demand filing of tax return if present year tax return is not available. If a parent believes that their taxable income will be lower than the amount used by the IRD in completing the formula assessment, they may apply to IRD to have their income estimated for the purposes of their child support assessment. If the estimate is accepted, their child support will be reassessed.
US: Vermont	The starting point for the calculation is gross income of both parents. It includes all types of income. Income does not include child support payments received or paid. Source of information obtained: parents are to provide information.	Standard tax rates are deducted; tables are used. The Gross to Net Income Conversion Table contains separate columns for the receiving parent and paying parent.	No. Although in calculating net income of taxes, the tax parameters include a basic personal amount.	Yes – if applicable. The amount for this adjustment is determined by using only the claiming parent’s net income to look up the amount of the adjustment in the Vermont Table of Intact Family Expenditures on Children. This amount is then subtracted from the Monthly Net Income Available for Child Support of that parent.	Monthly Net Income Available for Child Support.	If a parent is unemployed, underemployed, or fails to provide adequate documentation of their wages, the court may attribute income to them. In order to determine how much income will be attributed to the parent, the court examines earnings history, employment qualifications, and the current job market.
US: Wisconsin	The starting point for the calculation is gross income of the paying parent. It includes all types of income. Source of information obtained: parents are to provide information.	No	No	No	Annual Gross Income	The court may impute income based on earning capacity. In situations where the income of a parent is less than the parent's earning capacity or is unknown, the court may impute income for the parent at an amount that represents the parent's ability to earn, based on the parent's education, training and recent work experience.
US: Illinois	The starting point for the calculation is gross income of both parents It includes all types of income. Source of information obtained: parents are to provide information.	Standard tax rates are deducted using Illinois’ Gross to Net Income Conversion Table Using Standardized Tax Amounts.	No. Not explicitly, but there is personal exemption that is part of the gross to net conversion calculations- the Gross to Net Income Conversion Table Using Standardized Tax Amounts.	Yes - if applicable. Costs for other dependent children who are not part of this action, but child support paid and/or spousal support paid are deducted. Child support received or spousal support received - is an addition to income.	Adjusted Net Income	In cases of unemployment or underemployment, child support shall be calculated based on a determination of potential income. If there is insufficient work history, a rebuttable presumption is applied that the parent's potential income is 75% of the most recent United States Department of Health and Human Services Federal Poverty Guidelines for a family of one person.
US: Delaware	The starting point for the calculation is gross income of both parents. It includes all types of income. Source of information obtained: parents are to provide information.	No	Yes. A Self-Support Allowance is deducted from income for each parent.	Yes – if applicable. Deductions are allowed for medical and disability insurance premiums, pension deductions, union dues and court-ordered alimony and other child support order amounts.	Total Net Available Income for Primary Support.	If a parent is unemployed, underemployed, or fails to provide adequate documentation of their wages, the court may attribute income to them. In order to determine how much income will be attributed to the parent, the court examines earnings history, employment qualifications, and the current job market. Built into the model is the assumption that every parent has a “capacity to earn” at least an amount that is equivalent to half of the state-wide median wage for a 40-hour week.
Sweden	The starting point for the calculation is gross income of both parents. It includes all types of income. Source of information obtained: parents are to provide information.	A standard percentage of federal tax (31% of gross income) is deducted.	No	Yes. Subtracted from the net of taxes income are the parent’s monthly living expenses. These include: food, clothing, electricity, telephone, TV, insurance premiums, and travel to and from work. Also subtracted from the net income amounts are any housing expenses.	Surplus income after deductions	In Sweden, tax records are public. Thus, if either parent does not provide their income information, the courts will use these records to determine a parent’s most recent past earnings. Also, if a parent is underemployed or avoiding employment though qualified, the court has the discretion to establish an appropriate income level for the determination of child support.
Norway	The starting point for the calculation is gross income of both parents. It includes all types of income. Other benefits include cash benefit for the child with child support, extended child benefit and extra child allowance. Source of information obtained: parents are to provide information.	No	No	No	This amount is termed the Contributor’s Income for the paying parent and Beneficiary's Income for the receiving parent.	The Directorate of Labour and Welfare has discretion to attribute income to the paying parent if they are of the view that the amount of income that the paying parent is claiming is lower than what is reasonable based on their earning potential. The Directorate will use its discretion in determining the parent’s income and will base it on what they could have potentially earned in income.
France	The starting point for the calculation is gross income of the paying parent. It includes all types of income. Parents do not need to include as income, amounts aimed at improving the standard of living of children (e.g. family benefits) Source of information obtained: parents are to provide information.	No	Yes. The self-support reserve represents a “subsistence level” corresponding to the amount of the Revenue Active Solidarity (RSA). The amount of the RSA is updated annually.	No	Debtor's income after deduction	If a parent does not provide sufficient or, in the court’s opinion, accurate income information, the judge will order the parent to produce tax records and wage/salary slips to find the correct income level.

Table 8: Custody and Parenting Time Categories129
Jurisdiction	Custody and parenting time	Split custody or parenting situation
United Kingdom	Four “shared care bands” that reflect the number of nights spent with the paying parent are used to determine the reduction. Bands start at 52 nights per year (14%) and increase to greater than 175 nights per year (48% of the time). The deduction increases as time with the child increases.	In cases of split custody, each parent calculates how much they would pay in child support to the other parent for the child residing with that parent. The amounts would be compared, and the parent with the greater amount would pay the difference between the two amounts.
Australia	A person has shared care of a child if the person’s percentage of care for the child during a care period is at least 35% but not more than 65%. Below 35% but above 14%, a parent has regular care. Above 65%, a parent has primary care. The formula includes a Calculation of Cost Percentage for each child, for the time spent with each parent. It is subtracted from each parent’s income percentage and multiplied by the applicable amount from the Costs of Children Table. Each parent must have care of the child for at least 14% of the time (52 nights in a year, one day a week). The percentage increases with the amount of time spent with the child. If less than 52 nights, their “Cost Percentage” is zero.	For split custody where there are two or more children, child support amounts are determined for each child and based on the level of income and the percentage of parenting time. A child support amount is calculated for each child with each parent. Whichever parent has the most to pay after subtracting the other “paying parent’s” amount – he/she pays the difference.
New Zealand	There is no definition for shared custody. The formula includes a calculation of a Care Cost Percentage for each child, and for the time spent with each parent. It is subtracted from each parent’s income percentage and multiplied by the applicable amount from the Expenditure on Children Table. Each parent must have care of the child for at least 28% of the time (103 nights in a year, two days a week). The percentage increases with the amount of time spent with the child. If less than 103 nights, their Childcare Cost Percentage is zero.	For split custody where there are two or more children, child support amounts are determined for each child and based on the level of income and the percentage of parenting time. A child support amount is calculated for each child with each parent. Whichever parent has the most to pay after subtracting the other “paying parent’s” amount pays the difference.
US: Vermont	In situations where either parent has responsibility for the child for over 30% of the time (defined as overnight stays), the parents are considered to have a shared parenting arrangement. In these cases, the Tax Tables For Sole/Shared Custody Situations are used when calculating the income to be used. As well, the expenditures for the child obtained from the Expenditure Tables are increased by 50% and then divided between the parents in proportion to their incomes and time spent with the child. In situations where either parent has responsibility for the child for over 25% of the time but less than 30% (defined as overnight stays), the parents are also considered to have a shared parenting arrangement and the same calculations are completed. However, there is slight addition to the paying parent’s child support amount due to the fact that the receiving parent has the child for extra time between 25-30%.	In split parenting situations, where there is more than one child and each parent has physical custody of at least one but not all children, the support is calculated by completing two worksheets. Each worksheet is completed by calculating what the first parent would owe to the other parent if the child in their care were the only child of the parties. The parent who owes the greater obligation is ordered to pay the difference in support to the other parent. In split custody arrangements, the courts have the discretion to deviate from the guidelines
US: Wisconsin	Shared Placement Cases – Where parents have custody arrangements that allow for at least 25% (at least 92 days/year) of the time with the non-custodial parent. These cases require information on the monthly income for both parents. In cases where courts have ordered each parent to assume the child’s basic support costs in proportion to the time that the parent has placement of the child, the percentage standard found in the Standard Guideline is used. This percentage standard is applied to the monthly income of each parent. Each parent’s result is then multiplied by 150%. (This multiplier is designed to account for each parent’s share of the children’s basic support costs (food, shelter, clothing, etc.)). Then, each parent’s percentage of time with the child is calculated and applied to the other parent’s basic obligation. The two results are subtracted from one another, and the parent with the positive amount is the “shared placement”, paying parent.	Split-Placement Cases – Where there is more than one child and the children split residence time with both parents. These cases require information on the monthly income for both parents. In cases of split placement, the percentage standard that is used in the Standard Guideline is divided by the number of children. This provides a per child percentage. Then, based on the number of children each parent has, a relevant percentage is multiplied by the other parent’s monthly income. The resulting figures are compared and the parent with the higher amount pays that amount to the other parent.
US: Illinois	Non-Shared Parenting Time: There is no calculation for care of a child if the time spent with a parent is under 146 overnights (40%) on an annual basis. Shared Parenting Time: If each of the parents is responsible for the child for at least 146 overnight stays per year, the case is considered to be a shared parenting situation. In these situations, the Basic Support Obligation is multiplied by 1.5 to establish the Shared Physical Care Support Obligation. This amount is then prorated between the parties based on the combined net incomes of both parties. The respective Shared Physical Care Support Obligations are compared, with the parent owing more child support paying the difference between the two Shared Physical Care Support Obligation amounts.	Split Parenting: In split parenting situations, where there is more than one child and each parent has physical custody of at least one but not all children, the support is calculated by completing two worksheets. Each worksheet is completed by calculating what the first parent would owe to the other parent if the child in their care was the only child. The parent who owes the greater obligation is ordered to pay the difference in support to the other parent. In split custody arrangements, the courts have the discretion to deviate from the guidelines.
US: Delaware	Two adjustments are made to address the arrangements of parenting time. The first adjustment is in the calculating of primary support. If the child spends over 163 overnights (45%) of the time with the paying parent – they are considered as a ½ child in all calculations. The second adjustment is made when calculation the gross monthly child support obligation. If the child spends less than 80 overnights per year with the paying parent, no adjustment is made. If between 80 to 124 overnights per year, an adjustment of 10% is made, between 125 to 163 overnights per year, a 30% adjustment is made. The adjustments are made to the Standard of Living Adjustment (SOLA) for the parents. The resulting amounts are considered as credits and are subtracted from the paying parent’s net child support obligation.	In cases of split custody, and where each parent has children for over 163 overnights per year, both parents complete the calculations using the formula based on the number of children they have in their care. The parent with the higher Monthly Net Obligation will pay the difference to the other parent.
Sweden	If the child resides with both parents for an equal amount of time, neither parent is obliged to pay child support, regardless of any differences in income. A deduction from the child support amount for time spent with the paying parent is allowed. In situations where the child temporarily lives with the paying parent for at least six days of the month or for five consecutive days per month, a deduction of 1/40 of the child support amount per day that the child is in care can be made. This amount is then subtracted from the monthly child support amount.	There is no split custody, due to the discretionary nature of its child support model. The child support is not calculated unless one parent spends the majority of time with the children.
Norway	Norway uses a table to determine the parent’s Togetherness Amount to represent the amount of parenting time. The table contains five categories of the number of nights or days per month that the paying parent spends with the child by the age grouping of the children (there are five age groups). Each cell in the table provides the “togetherness costs”, costs that include: food and drink, health and hygiene, play and leisure, transportation, and building expenses (only if the time spent is nine or more days/nights per month).	The parents need to complete two formula calculations, each based on the number of children they have the majority of time in their household. The parent with the larger child support amount pays the other parent the difference between their two amounts.
France	Three categories of parenting time are used in the determination of child support. These are: Reduced: the child's residence is primarily with one parent and the other parent's residence time is less than 1/4 of the overall residence time. This may include unfamiliarity of access and accommodation due to unavailability of the parent, or simple access without accommodation, if the parent does not have adequate housing, or if that accommodation is not available, in the interest of the child; Classical: the residence is fixed mainly by one of the parents and the residence time of the other parent is equivalent to 1/4 of the total residence time (ex: one weekend out of two and half of the school holidays); Alternate: the children live alternately in the home of each parent. Alternate residence may be used as a contribution to the maintenance and upbringing of children when parents have not agreed on the sharing of child-related costs according to their resources, or when one parent cannot bear the financial burden of the alternating residence alone.	There is no split custody, due to the discretionary nature of its child support model. Child support is not calculated unless one parent spends the majority of time with the children.

Table 9: Treatment of Dependents Who Are Not Part of Current Child Support Assessment130
Jurisdiction	Dependent Children	Spousal	More than one dependent from previous relationships
United Kingdom	Yes – if applicable An amount is deducted from gross income. This is an allowance for children who are not the subject of the assessment but are in the care of either parent.	Spousal maintenance is not taxable income and therefore not included as income for child support purposes.	Children for whom child support is being paid for are explicitly excluded from the formula calculations.
Australia	Yes – if applicable. Dependent Children allowance. This allowance is for children who are not the subject of this assessment but are in shared care of the parent for a least 35% of the time. A Dependent Children Allowance is deducted from a parent's Adjusted Taxable Income when working out their child support income.	Spousal maintenance is not taxable income and therefore not included as income for child support purposes.	Yes – if applicable. Multi-case allowance. If a parent has been assessed for the costs of the children of more than one relationship (that is the parent has multiple child support cases), then a Multi-case Allowance is deducted from a parent's Adjusted Taxable Income when working out their child support income.
New Zealand	Yes – if applicable. Dependent Children allowance. This allowance is for children who are not the subject of this assessment but are in the care of the parent for a least 28% of the time and to whom the parent has a legal liability.	Spousal maintenance is not taxable income and therefore not included as income for child support purposes.	Multi-group allowance. If a parent has been assessed for the costs of the children of more than one relationship (that is the parent has multiple child support cases), then a Multi-group Allowance is deducted from a parent's Annual Adjusted Taxable Income when working out their child support income.
US: Vermont	Yes – If applicable. After the net monthly incomes are determined for both parents, an adjustment for additional dependent children may be made. If there is an existing child support order, the amount of the order is subtracted from the parent’s adjusted income.	Spousal support, or maintenance, (that is not taxable and already included or deducted as income) received is added in the receiving parent’s net income and deducted from the paying parent’s net income. (Note: Federal tax rules for spousal support changed as of January 1, 2019)	If there is an existing child support order, the amount of the order is subtracted from the parent’s net monthly income.
US: Wisconsin	Yes – if applicable. A separate formula is applied if there are other dependent children – the serial family guideline is used, with separate calculations for each child from a different family and ordered by date of birth of children.	Spousal support is not included as a deduction or inclusion for purposes of income determination.	Serial Family Cases – For a serial-family131 parent where the child support obligation is incurred for a marital or non-marital child in a subsequent family. The child support obligation must be as a result of a court order. In cases where the court agrees that there is more than one child support obligation for a paying parent, it will first subtract the amount of the existing child support obligation from the parent's monthly income available for the new child support obligation. The percentage standard that is used in the Standard Guideline is then applied to this adjusted monthly income.
US: Illinois	Yes – if applicable. Covered under the Multi-family Order Adjustment.	Spousal support, or maintenance, (that is not taxable and already included or deducted as income) received is added in the receiving parent’s net income and deducted from the paying parent’s net income. (Note: Federal tax rules for spousal support changed as of January 1, 2019)	Called a Multi-family Order Adjustment. It is used for one or many dependent children not part of the current action. Under these two circumstances a parent may claim this adjustment: Where there is a court order for child support being paid, that amount may be deducted from the parent’s net income. Where there is no court order, but it is established that a parent has responsibility for a child either living in or outside their household, the court shall deduct from the parent's net income the amount of financial support actually paid by the parent for the child, or 75% of the support the parent should pay under the child support guidelines (before this adjustment), whichever is less. Only the responsible parent’s income is to be used.
US: Delaware	Yes – if applicable. There is a deduction for Other Dependents from a parent’s available income to recognize the parent’s duty to support all their children. Stepchildren are excluded and children outside the household are only counted if there is a court order for support or there is a pattern of support established.	Spousal support, or maintenance, (that is not taxable and already included or deducted as income) received is added in the receiving parent’s net income and deducted from the paying parent’s net income. (Note: Federal tax rules for spousal support changed as of January 1, 2019)	See Dependent Children column.
Sweden	Yes – if applicable. The parent may also set aside (reserve) an amount for maintenance of a spouse with whom they permanently live, for example, following remarriage. With regards to other dependent children, the paying parent may deduct for each dependent child an amount, that together with the amount that is to be paid to the parent for the child for whom child support is being determined, constitutes up to 40% of the applicable price base amount.	No deductions are made for spousal support paid nor is it included in income.	See Dependent Children column.
Norway	Yes – if applicable. BUT – can only be considered when assessing capacity to pay for the paying parent. See Undue Hardship below.	Spousal support is not included in the determination of income.	If the paying parent pays child support to multiple receiving parents and does not have enough income to pay all the contributions, the older child support amounts may be reduced.
France	Yes – if applicable. When calculating the amount of child support payable, the total number of children for which the paying parent has legal liability is used. This is because the underlying policy is that the paying parent has a responsibility towards each of those children.	Spousal support is not included in the determination of income.	See Dependent Children column.

Table 10: Treatment of Special Expenses132
Jurisdiction	Childcare	Medical	Education	Extracurricular activities
United Kingdom	A paying parent may request that the Child Maintenance Service take certain special variation expenses into account. These create a variation from the maintenance calculation and can reduce the paying parent’s gross income. Depending on the type of expense and its periodicity, the paying parent’s income may be adjusted accordingly. An application for a special variation expense may be made for: Costs connected with supporting a child with a disability or a long-term illness who lives with the paying parent or their partner; or Boarding school fees for a child or children that qualify for child maintenance – but only the everyday living costs or ‘boarding’ part of the fees (must be at least £10 a week).
Australia	“Special Expenses” are dealt with outside the formula calculations. However, the Registrar is authorized to change a formula assessment to include additional expenses. These costs are evaluated and incorporated into the child support amount where appropriate. Reasons related to this section include: The costs of maintaining a child are significantly affected by high costs associated with the child's special needs; The costs of maintaining a child are significantly affected by high costs of caring for educating or training the child in the way both parents intended; or The costs of maintaining a child are significantly affected by the high childcare costs for the child (and the child is under 12 years of age).
New Zealand	“Special Expenses” are dealt with outside the formula calculations as one of the twelve “grounds for administrative review”. These costs are evaluated and incorporated to the child support amount where appropriate for either parent. Two of those “grounds” related to this section are: Extra costs to cover the child (or children's) special needs, Extra costs to care for educating or training the child (or children) in the way that was expected by either parent.
US: Vermont	The court has discretion to add childcare costs to the basic child support amount. Costs are apportioned between the parents based on their percentage of the combined child support income.	Expenses for special educational costs, qualified childcare costs and medical expenses are added to the amount obtained from the Vermont Table of Intact Family Expenditures on Children, to form the Combined Family Expenditures amount.
US: Wisconsin	Special expenses or “variable costs" refer to the reasonable costs above basic support costs incurred by or on behalf of a child. These costs include but are not limited to, the cost of childcare, tuition, a child's special needs, and other activities that involve substantial costs. These costs are only applied in “shared-placement” or in “a combination of special circumstances”. The costs are to be split in proportion to each parent’s time spent with the child. Furthermore, these costs are to be split between the parents in shared-placement cases based on their proportion of time with the child. For medical costs, Wisconsin rules under DCF 150.05 Medical Support lay out the circumstances and rules for assigning the parents responsibility for providing the child with a private insurance, if applicable and available.
US: Illinois	The court has discretion to add childcare costs to the basic child support amount. Costs are apportioned between the parents based on their percentage of the combined child support income.	The court has discretion to add costs for ordinary medical costs (e.g. health insurance premiums) to the basic child support amount. Costs for special medical or development needs are considered a deviation from the rebuttable presumption from the calculated child support amount. The court must provide reasons for deviation in writing. All costs are apportioned between the parents based on their percentage of the combined child support income.	The court has discretion to add reasonable costs for school and/or extracurricular activities to the basic child support amount. Costs are apportioned between the parents based on their percentage of the combined child support income.
US: Delaware	Childcare costs, medical expenses (not including insurance premiums) and private tuition are called Primary Expenses and are included in the formula as part of the calculation of the child’s Primary Support Need. All of these expenses must be verified and agreed upon by the parents			Extracurricular activities are excluded from the formula calculations.
Sweden	Childcare costs are included in the formula calculations and form part of the total child costs.	Sweden’s child support legislation is silent on the issue of special expenses.
Norway	These costs are called supervisory costs and are included by the receiving parent as part of the total costs of a child.	Limited special expenses are eligible for consideration and are added to the Maintenance Cost amount, which are then shared proportionally. Examples include the cost of braces, glasses and lenses. Not included are other special expenses such as: the cost of recreational activities, sports equipment, musical instruments and travel. The parent who incurs these expenses may apply to the National Office for Social Insurance Abroad (NAV) to have them considered in the determination of the final child support amount.
France	In France, the determination of child support does not recognize per se, special expenses such as extra medical or private tuition etc. The individual court and judge have the discretion to include any expenses they deem appropriate in the determination of a child support amount.

Table 11: Variations, modifications and updating to child support amounts133
Jurisdiction	Undue hardship	Variations/modifications	Updating of tables and expenditure data and child support amounts
United Kingdom	Adjustments for the concept of “undue hardship” (e.g. additional expenses, debts, etc.) are considered as “special variation expenses” and if approved, are deducted from the paying parent’s income.	A variation to a maintenance amount will only be considered if the amount of the current income of the paying parent has changed by at least 25%.	An annual review of each child maintenance case is completed by the Child Maintenance Service and occurs every 12 months, based on the anniversary date on which the paying parent was advised that there was a child maintenance application.
Australia	Under the “Reasons” for the Registrar to depart from the formula assessment (parents may apply for one of these “special circumstances”) are the following situations that may be considered as “undue hardship”: The child support assessment is unfair because of the income, earning capacity, property or financial resources of one or both parents; The parent's capacity to support the child is significantly affected by their duty to maintain another child or person; or The costs of maintaining a child are significantly affected by high costs of enabling a parent to spend time with, or communicate with the child.	If the assessment of the amount of child support is different by more than 15% from the previous assessment due to circumstances not contemplated by the previous agreement—a party to the previous agreement must give the Registrar written notice of the termination of the agreement within 60 days of that party receiving notice of the variation. Also, if the previous agreement was made three or more years earlier—a party to the previous agreement needs to give the Registrar a written notice of the termination of the previous agreement.	Basic values used in calculating child support assessments are updated before the end of each calendar year. They are: The minimum annual rate of child support; The fixed annual rate of child support; and The Costs of the Children Table.
New Zealand	Under the “Grounds for Administrative Review”, parents can claim the following: The parent has a duty to maintain another child (or children) or person; It costs the parent extra to cover the special needs of another child or person; The parent has necessary expenses in supporting themselves; The parent’s contact costs are more than 5% of their adjusted taxable income; The parent still has a financial interest in a property that the other person is entitled to live in; or The child support assessment includes extra income earned from additional work to cover costs of re-establishment after separation.	A Child Support Order can be modified or varied provided that it is satisfied that: Making the variation is justified because of a change in the circumstances of the child, the receiving parent, or a liable parent concerned since the order was made or last varied; or Making the variation is justified because of a change in the “all groups index number” of the New Zealand Consumer Price Index since the order was made or last varied. At least 12 months must have elapsed since the order was made or was last varied having regard to such a change.	The income categories for the Child Expenditure Table, the living allowances and the minimum support amounts are updated annually by an inflation factor.
US: Vermont	Yes – a component of the guidelines calculation is an “ability to pay” assessment.	On motion of either parent, the Office of Child Support (OCS), any other person to whom support has previously been granted, or any person previously responsible for support, and provided that there is a real, substantial and unanticipated change of circumstances, the court may annul, vary, or modify a child support order. If the court has not modified the child support order for at least three years, the court may waive the requirement of a showing of a real, substantial, and unanticipated change of circumstances. The OCS may independently file a motion to modify child support if a party is or will be incarcerated for more than 90 days, if the family has reunited or is living together, if the child is no longer living with the payee, or if a party receives means-tested government benefits. A child support order that varies more than ten percent from the amounts calculated under the Vermont Guidelines shall be considered a real, substantial, and unanticipated change of circumstances.	Administrative reviews: The Office of Child Support can make these reviews when a change occurs that is required by law, such as when a parent under a current child support order misses their payments for one calendar month. An arrears payment will automatically be added to the order.
US: Wisconsin	Either parent can request a deviation to any of the six formulas if they provide evidence that the use of the applicable formula relevant to their circumstance is unfair to the child or to any of the parties. Various reasons for consideration for a deviation that relates to undue hardship are provided for. These include: The award of substantial periods of physical placement to both parents; Extraordinary travel expenses incurred in exercising the right to periods of physical placement; The physical, mental, and emotional health needs of the child, including any costs for health insurance; and The tax consequences to each party.	Once a child support order has been established, it can only be changed if there has been a substantial change in circumstances. Examples of what constitutes a change in circumstances include: A substantial change in the income of either party. The definition of “substantial” is often based on the facts of the situation, but usually this requires a change in gross income of at least $5,000 per year or more, which results in a substantial change to the child support award. If at least 33 months have passed since the last child support order, a substantial change in circumstances is presumed to have occurred. A change in the placement (parenting time) schedule. A move by one party or the other resulting in additional transportation costs. A substantial change in the needs of either parent or the child. For example, if a child develops special needs, incurs unusual costs or if a parent becomes disabled.	There is no administrative review of child support orders (or amounts), as the court is the only place where an order may be modified and only at the request of one of the parties.
US: Illinois	The formula shall be rebutted upon a preponderance of the evidence that the results are not in the best interests of the child or are inequitable to the parties. The formula may be rebutted in whole or in part. Every order rebutting the formula shall state the reason for the deviation. The Court may decline to adopt any agreement deviating from the formula that is clearly contrary to the best interest of the child.	Not less than once every three years, the Department of Child Support Services notifies each parent subject to a child support order of the right to request a review of their order. Orders qualify for the modification review process if one of the following conditions exists: At least three (3) years have passed since the establishment of the order or the last modification review; or There is a substantial change in the non-custodial parent’s income; or The order does not address healthcare coverage for the child; or The modified child support amount deviates from the previous Illinois guidelines amount by more than 20% and at least $10.	See Variations and Modifications.
US: Delaware	Included in the Melson Formula is a final step in the formula calculations that is designed to ensure that the final child support amount for the paying parent does not cause undue hardship as a result of existing support obligations for other children in other households.	If the parties agree, they can amend the child support amount by writing a new agreement. This also applies in cases where the child support amount was previously decided by a judge. If the parties cannot agree, they must apply to a court in order to have a previously decided child support amount amended. The court can amend the child support if the circumstances have changed. Generally, the change in circumstance must be significant and judges have discretion as to whether the child support amount should be amended.	There is no regular, periodic updating or review of child support amounts.
Sweden	If the paying parent does not have the ability to pay, child support will not be ordered.	The court can also adjust an agreement that, in their opinion, is unreasonable considering the circumstances of the parties at the time the agreement was established.	There is no regular, periodic updating or review of child support amounts.
Norway	The last step in the calculation of child support is an assessment of the ability of the paying parent to pay the Final Guidance Amount to ensure that the paying parent has the ability to pay, and at the same time, has enough funds left to support themselves and any other children for whom they are legally liable and that reside in their household.	An application may be made to modify child support payments, determined by the administrative agency, if there are special reasons for doing so. The reasons can be as a result of a change in the age of the child, a change in income, residence or time spent with the child.	All child support agreements are index-linked unless it is otherwise stated in the decision or the agreement. Indexation is linked to any change in the consumer price index issued by Statistics Norway.
France	The determination of child support does not provide for the concept of undue hardship, or the inability to pay. The courts and judges consider specific case circumstances as they arise.	In the case of new elements in the personal and / or financial situation of the paying or receiving parent, it is possible to request a revision to the child support amount. In these cases, the amount may be modified (upwards or downwards).	Tools are available to adjust the child support amount to reflect yearly changes to the consumer price index. In order to reassess the amount of the support, the judgment or order made by a judge must mention the indexation of the award to reflect changes to the consumer price index. Parents may also update their child support amounts themselves to reflect the current consumer price index using an online tool. In general, the revaluation is scheduled every year on a fixed date (e.g. the anniversary date of judgment).

Table 12: Other Considerations134
Jurisdiction	Age of child	Minimum orders	Maximum orders	Treatment of low- or high-Income earners	Capping or marginal tax rates
United Kingdom	An order or agreement terminates when the child reaches 16 or 20 if they are in full time education.	If a prospective paying parent earns less than 7£ per week, no order is made.	Guidelines do not apply if the paying parent makes over 3000£ per week.	See Minimum orders and Maximum orders.	No
Australia	The agreement automatically terminates when all minor children have reached the age of 18 years of age; 19 if the child is still in school and/or graduates from high school, whichever occurs first.	A minimum annual amount of child support is set each year. For the child support year April 1, 2019 to March 31, 2020, the amount is $435/year or $36/month per child.	In cases where the paying parent is a high-income earner, child support amounts are effectively “capped” when the income amounts exceed 2.5 times the Average Weekly Earnings. The Child Expenditure Table does not provide amounts above that combined net income level. For the child support year 2019, the amount is $187,785 AU annually.	See Minimum orders and Maximum orders.	No
New Zealand	Agreements automatically terminate when all minor children have reached the age of 18 years of age; 19 if child still in school and/or graduates from high school, whichever occurs first.	A minimum annual amount for child support is set each year. For the child support year April 1, 2019 to March 31, 2020, the amount is $919/year or $77/month per child. Exemptions are allowed for hospital patients, prisoners, and persons less than 16 years, if they have no income.	In cases where the paying parent is a high-income earner, child support amounts are effectively “capped” when the income amounts exceed 2.5 times the Average Weekly Earnings. The Child Expenditure Table does not provide amounts above that combined net income level.	See Minimum orders and Maximum orders.	None
US: Vermont	Agreements automatically terminate when all minor children have reached the age of 18 years of age; 19 if child still in school and/or graduates from high school, whichever occurs first.	No formal minimum but court can take income of parent’s into consideration and can deviate from the guidelines.	No	The court may use its discretion in determining child support in circumstances where the combined available income exceeds the uppermost levels in the Vermont Table of Intact Family Expenditures on Children.	None
US: Wisconsin	Agreements automatically terminate when all minor children have reached the age of 18 years of age; 19 if child still in school and/or graduates from high school, whichever occurs first.	If a paying parent’s monthly income available for child support is below 75% of the Federal Poverty Guidelines, the court may order an amount appropriate to the paying parent’s total economic circumstances.	If the paying parent makes more than $12,500 per month, the guidelines do not apply and the court has discretion to set a child support amount.	Two formulas are set out in legislation to set child support amounts in cases of a: High-Income Payer – Where the gross income from all sources of the paying parent is $7,000 per month or more ($84,000 per year). Low-income Payer – Where the gross income from all sources of the paying parent is less than 150% of the Federal Poverty Guidelines (FPG) for a single person.	None
US: Illinois	Agreements automatically terminate when all minor children have reached the age of 18 years of age and graduated from high school. If the child is over 18 and has not finished high school, the child support will be terminated when the child is 19 or when the child receives a high school diploma – whichever occurs first.	For a parent with gross income either at or below 75% of the Federal Poverty Level, child support is set at $40.00 per month per child with a cap set at $120 per month. In cases where parents have no gross income and receive means–tested income, or cannot work for medical reasons, are incarcerated or are in an institution, there is a rebuttable presumption that the $40 per month minimum order is inapplicable and a zero amount can be ordered.	No	The Schedule of Basic Child Support Obligations sets out amounts of child support up to a combined monthly net income of $300,000 per month. Courts may use their discretion to determine the appropriate child support amount beyond that monthly net income amount.	None
US: Delaware	Agreements automatically terminate when all minor children have reached the age of 18 years of age and graduated from high school. If the child is over 18 and has not finished high school, the child support will be terminated when the child is 19 or when the child receives a high school diploma – whichever occurs first.	If the children reside in a sole custody situation (less than 79 overnights per year), the court can impose a minimum order of no less than $100 per month for one child, and $170 per month for more than one child.	No	If a parent’s income available for the Standard of Living Adjustment exceeds $15000, 20% of the difference is calculated and is identified as the High Income Offset. This amount is subtracted from the income available for the Standard of Living Adjustment calculations.	There is a Self-Protection amount calculated at the end of the normal formula calculations that “caps” the amount of Primary Support Income that is used for child support. The caps are presented as percentages of income.
Sweden	By statute, child support orders will be terminated the month the child turns 18. Any extension for child support beyond the age of 18 requires that the child attend a secondary school. When the child turns 18, the child becomes a legal party to the proceedings and the child must put forward the claim for support. The child is entitled to child support up until their 21st birthday. For schooling, studies in compulsory school or upper secondary school or other comparable basic education are included. The parents should share these costs with each other according to their ability.	A parent who does not have any capacity to contribute to the child’s support is not liable to pay child support.	No	No	None
Norway	By statute, child support decisions will be terminated the month the child turns 18. An extension for child support beyond the age of 18 requires that the child attend secondary school. When the child turns 18, the child becomes a legal party to the proceedings and they must put forward any claim for support. Attendance at a university normally does not qualify for a consideration of child support.	No	There is no fixed “maximum” amount of child support; however, the formula calculations include a limit on the amount of child support based on the paying parent’s ability to pay. There are also two other “limits” that can be considered. These are: the paying parent shall not pay more than 5/6 (or 83.3%) of the Maintenance Cost of the child nor shall they pay more than 25% of the calculated gross income before any allowance.	No	No
France	Parents have the obligation to provide material support to their adult child if they are not financially independent. The amount of this assistance varies according to the resources of the paying parent and the needs of the child. Once a child is in a position to cover their own needs and has completed, where applicable, secondary or tertiary/university education, child support is payable to them.	The Table of Child Support only applies to the paying parent whose monthly income and resources are EUR 700 or more.	No	No	No

Footnotes

99 “Starting” income in this context means the first type of income (usually gross income) that jurisdictions require for the determination of child support amounts.

100 Jane Venohr, Technical Documentation: Illinois Schedule of Basic Obligations and Standardized Net Income Table, June 12, 2017 (revised), 19, 38.

101 Self-support reserves serve two purposes in some jurisdictions. They are deducted directly from gross income and are also used as a measure of the paying parent’s ability/capacity to pay as explained under the section describing undue hardship.

102 Australia, New Zealand, Delaware, Vermont, France, Illinois.

103 Use of the “dependent child” factor is not confined to just deducting it from income. This is explained later in this chapter.

104 Jane Venohr, Child Support Guidelines and Guideline Reviews: State Differences and Common Issues, 343.

105 Ibid, 343.

106 Australia, New Zealand, United Kingdom, Delaware, Vermont, and Illinois.

107 Delaware’s deduction occurs in the first step of its formula, the income shares step.

108 Wisconsin, DCF Chapter 150.04, Determining the child support obligation in special circumstances. (1) Determining the Child Support Obligation of a Serial-Family Parent.

109 Counting the number of overnights is the standard for all jurisdictions; however a number of jurisdictions have additional methods for counting time spent with the child, e.g. counting days, or if a certain number of hours in a day (e.g., seven hours) is met, those days are counted also as time spent, etc.

110 Wisconsin’s DCF 150.04(3) and Vermont’s 15 V.S.A. § 657 are two examples of split custody rules laid out in legislation.

111 Recall that in a percentage of income model, the child support amount is calculated by multiplying a standard percentage (which represents the cost of the child) by the income of the paying parent.

112 To understand these complex calculations, the reader is advised to review the individual jurisdiction summaries in Volume II.

113 Sweden defines parenting time in blocks of continuous time, at least five days, while Wisconsin counts hours of the day, with a minimum of six hours considered as time spent.

114 Alternate residence may be used as a contribution to the maintenance and upbringing of children when parents have not agreed on the sharing of child-related costs according to their resources or when one parent cannot bear the financial burden of the alternating residence alone.

115 This is a very different order of calculations from the other jurisdictions that is unique to Australia and New Zealand. For more detail on this aspect of their formula calculations, please see the Australia and New Zealand Summaries in Volume II.

116 Please refer to the Delaware Summary for more detail on the calculations for the parenting time adjustment.

117 Australia, New Zealand, United Kingdom, Vermont, Illinois and Delaware.

118 For a serial-family parent, the child support obligation is incurred for a marital or non-marital child in a subsequent family.

119 Please refer to Section E in this report for a discussion on how jurisdictions account for “ability to pay” or undue hardship.

120 Tax Cuts and Jobs Act, 2017, Public Law 115-97, 115th Congress.

121 One of the reasons for departing from the formula amount in Australia is: “The costs of maintaining a child are significantly affected by the high childcare costs for the child (and the child is under 12 years of age).”

122 In Wisconsin, only medical care premiums are considered in the model.

123 Family Support Act of 1988, Pub. L. No. 100-485, 102 Stat.2343.

124 This is only part of its formula calculations that Vermont uses a self-support reserve amount; it does not use it as part of income determination as other jurisdictions do.

125 Family Support Act of 1988, Pub. L. No. 100-485,102 Stat.2343.

126 Australia, New Zealand, Delaware and France have explicit self-support reserves. Vermont and Illinois have a basic personal amount embedded in their standard tax conversion tables that is similar to a self-support reserve.

127 United Kingdom, Australia, New Zealand, Vermont, Illinois and Delaware.

128 There is significant information on this element of the guidelines that could not be placed into tabular format. Details for each jurisdiction can be found in the summary reports in Volume II.

129 There is significant information on this element of the guidelines that could not be placed into tabular format. Details for each jurisdiction can be found in the summary reports in Volume II.

130 There is significant information on this element of the guidelines that could not be placed into tabular format. Details for each jurisdiction can be found in the summary reports in Volume II.

131 For a serial-family parent, the child support obligation is incurred for a marital or non-marital child in a subsequent family.

132 There is significant information on this element of the guidelines that could not be placed into tabular format. Details for each jurisdiction can be found in the summary reports in Volume II.

133 There is significant information on this element of the guideline that could not be placed into table format. Details on each of these elements can be found in the individual Summary Reports by jurisdiction in Volume 2.

134 There is significant information on this element of the guidelines that could not be placed into tabular format. Details for each jurisdiction can be found in the summary reports in Volume II.

Date modified:: 2022-11-15

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