The appellant appealed a determination by the Minister of National Revenue that a worker hired as a concierge was engaged in insurable employment under a contract of service from January 1, 2018, to September 17, 2018.
The Tax Court of Canada reviewed the relationship under the Civil Code of Québec and common law indicia, finding that despite the appellant's intention to create an independent contractor relationship, the objective reality demonstrated subordination, control, provision of tools, and integration into the appellant's business.
The appeal was dismissed, affirming the Minister's determination that the employment was insurable.