The appellant appealed a determination by the Minister of National Revenue that a worker was engaged in insurable and pensionable employment.
The appellant argued the worker was an independent contractor.
Applying the Connor Homes two-step test, the Tax Court found that while the parties intended an independent contractor relationship, the objective reality—including the payer's control, provision of tools, and lack of financial risk for the worker—demonstrated an employer-employee relationship.
The appeal was dismissed.
