In the Drygala v. Pauli case, the court made a significant decision regarding the imputation of income. Despite Mr. Pauli being a full-time university student with no full-time employment, the court imputed an annual income of $30,000 to him. The court arrived at this decision based on the belief that Mr. Pauli, given his skills and qualifications, was capable of working part-time while attending school. This decision underscored the principle that child support obligations cannot be circumvented through intentional unemployment or underemployment, even if the parent is pursuing education.

The Ontario Court of Appeal has provided clarification regarding imputing income in cases of intentional underemployment or unemployment. In accordance with section 19(1)(a) of the Guidelines, it has been established that it's not essential to prove bad faith or an attempt to evade support obligations to impute income. A parent can be deemed intentionally underemployed if they earn less than they are capable of earning, given all of the relevant circumstances.