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Oil coming from rear diff. Appears to coming from up top
That's not likely a leak in the differential, although there is a vent at the top, and if somehow it's overfilled (hard to do) or the fluid is foaming, I guess it could leak out the vent.

However, Subaru has used oil-filled bushing in different places over the years, including the differential mounting bushings in the 4th gen. Here's a thread with the same issue, and a link to an earlier one:

 

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Discussion Starter #3
So the bushings at the top of the picture could be oil filled? That would make sense as there is a lot more oil around the frame member below the bushings than there is on the differential AND it doesn’t smell like gear oil. What’s the harm in just letting it go?
 

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Give it a good clean and scrub so you can possibly see where it is leaking better. Could be the bushings for sure; you can always pull the fill plug to see where the level is at.
 
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