Princess Okechukwu

The Appellant appealed a decision of the Minister of National Revenue confirming a CRA ruling that a licensed crop hail adjuster worked as an employee rather than an independent contractor during the summer of 2016.

The Tax Court of Canada allowed the appeal, finding that the parties intended an independent contractor relationship and that the objective factors, including lack of control and provision of his own vehicle, supported that the worker was in business on his own account.

The appellants, quarterly tax remitters, underestimated their tax installments for the first three quarters of 2019.

They argued that a large, unanticipated dividend declared in November 2019 caused the deficiency, making it impossible to foresee the increased tax liability.

The Tax Court of Canada dismissed the appeals, holding that the appellants chose to estimate their taxes rather than use the safe-harbour no-calculation option based on the previous year.

Because the dividend was a deliberate tax planning choice and not an unforeseeable event, the appellants were liable for the resulting arrears interest and penalties.

The appellant appealed the Minister's redetermination of her Canada Child Tax Benefit and HST credits for the 2012 and 2013 base years.

The Minister reduced her benefits by half after determining she had a shared custody arrangement, despite the appellant having previously disclosed this arrangement to the CRA.

The Tax Court of Canada dismissed the appeal, holding that the Minister is not bound by prior errors or knowledge and has no equitable jurisdiction to grant relief based on fairness or estoppel.