The Appellants appealed the Minister's decisions that their employment with their family business was not insurable employment.
The Minister determined they were excluded because they controlled more than 40% of the voting shares and did not deal at arm's length with the employer.
The Tax Court of Canada found that the Appellants had effective control of 100% of the voting shares, despite their daughter nominally holding 70% of the shares.
The Court also found they did not deal at arm's length, as they worked for below-market wages and without remuneration.
The appeals were dismissed.
