November 22, 2005
Case Law Development: Effect of Currency Exchange Rate on Modifications of Child Support
When an obligor parent is working abroad, how should changes in the exchange rate be taken into consideration in modifying child support. In this case, the Supreme Court of Alaska held that fluctuations in the exchange rate could not be considered additional “income” for purposes of modifying child support. Rather, the parent’s income should be converted to dollars and then used to calculate support. If the resulting change in amount meets the statutory presumption for changed circumstances, the court should modify the child support amount.
Hixson v. Sarkesian, 2005 Alas. LEXIS 159 (November 18, 2005)
Opinion on the web at http://www.state.ak.us/courts/ops/sp-5958.pdf (last visited November 21, 2005 bgf)