The appellants appealed the Minister's decisions that they were employed in insurable and pensionable employment with Serve Media Inc., a company owned by their parents.
The appellants performed internet marketing tasks, such as posting ads on Kijiji, and invoiced the company for their work.
The Tax Court of Canada allowed the appeals, finding that the appellants were independent contractors bound by contracts for services.
The court noted that the company did not exercise control over the timing and manner of the work, the appellants provided their own equipment, and there was an opportunity for profit.
