The damages expert should include any and all sources of earnings at the time of the event that gives rise to the loss. The emphasis is to measure earnings from activities of the plaintiff. Passive income, yields such as stock dividends, interest on bonds, pension payments, or related income are excluded. Although earnings types will vary from case to case, the following list is representative of what should be considered:
- Regular pay and salary
- Overtime pay
- Commissions, bonuses and stock options
- Income from second jobs
- Self-employment Income
- Fringe benefits from all jobs, including health insurance, retirement, etc. Perks such as use of a company car, club memberships or similar benefits of a job should also be considered.