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Perreault can be considered theoretical. As for the hours of work, since Ms.  ...

However, simply referring to the Minister's discretion is misleading. [27]     In light of the above, this Court must conclude that the employment of the Appellant is an excluded employment under paragraph 5(2)(i) of the Employment Insurance Act. [28]     Furthermore, this Court concludes that the Minister correctly exercised his discretion under paragraph 5(3)(b) of the Employment Insurance Act. [29]     Having heard the evidence adduced at this hearing and having examined the documents produced, this Court is of the view that the Minister's conclusion, when considered with the evidence brought before it at this hearing, still seems reasonable. [30]     Therefore, this Court does not deem appropriate, in the circumstances, to interfere with the Minister's determination. [31]     Consequently, the appeal is dismissed and the Minister's decision is confirmed. ...

The Appellant is clear that he has always considered Ms. Vrdoljak to be self-employed. ...

., [2001] 2 C.T.C. 2048, Tardif, J. considered a corporate appellant's inability to pay a lawyer's fees as 'a decisive factor' in such a motion as this. [6]      David-Kevin: Lindsay is not an officer of the Appellant. ...

In this case, Ron filed a Notice claiming Robert and Tyson as his qualified dependants for the period from July 2002 to October 2003 because he claimed that they resided with him at his house one and a half blocks from Michelle's house. [5]      Regulation 6302 describes the factors to be considered in what constitutes care and upbringing of Tyson and Robert in these circumstances. ...

Therefore, your correspondence cannot be considered as a valid Notice of Objection under the Income Tax Act. ...

All things considered, I found Exhibit A-1 and Exhibit R-1 to be so fundamentally unreliable that I gave little weight to either set of documents ...

This factor in a way supports the Minister's view that the duties did not justify 20 hours of work per week. [32]     On that basis, it can reasonably be considered that the payer would not have hired a person who did not know how to operate a computer on conditions similar to those granted to the appellant. [33]     In conclusion, I find that the evidence brought by the appellant and her spouse, Mr. ...

The Minister also determined that the Appellant and the Payer were not considered to be dealing at arm's length for the purposes of this job, since he was convinced that it was reasonable to conclude that the Appellant and the Payer would have had a similar contract of employment if they had been dealing at arm's length, considering the following circumstances: (a)         The sales director and the editor in chief also receive monthly bonuses calculated based on sales transactions; (b)         The sales director also had the use of a car belonging to the Payer; (c)         In 2002, the editor in chief's pay was $50,225, and that of the sales director was $47,183; (d)         In 2002, the Appellant's $49,333 pay was reasonable considering the duties she carried out; (e)         The Appellant sets her own work schedules, which vary according to the Payer's needs; (f)          She works evenings or weekends according to the Payer's needs; (g)         The number of hours she works can sometimes vary between 30 and 45 hours per week; (h)         Considering the Appellant's experience and her position, it is normal for her to be able to make everyday decisions on a normal business day without referring to the Payer's administrator; (i)          The Appellant works year-round, in accordance with the company's activities; (j)          The Appellant's duties, as executive director, were necessary for the Payer's company. [3]      All the facts alleged in paragraphs 6, 7 and 8 of the Reply to the Notice of Appeal were admitted, except for those in: (i)                 subparagraphs 6(g), 6(l), 6(m), 6(n), 8(d), 8(e), 8(f) and 8(g), which were denied; (ii)               subparagraphs 6(h), 6(k), 6(p), 6(r) and 8(a), which were also denied as written; (iii)             subparagraph 6(e), which was admitted but subject to completion. [4]      It must be noted that at the beginning of the hearing, the Appellant's representative admitted that the Appellant performed employment for the Payer under a contract for services. [5]      It must be stated that the Respondent determined that this was insurable employment because it did not fall under paragraph 5(2)(i) of the Employment Insurance Act (the "Act"). ...

The Appellant objected to the May 24, 2002 assessment by filing a Notice of Objection dated August 15, 2002, in which he requested to be considered a non-resident of Canada for tax purposes from January 31, 1997 based on article IV of the Canada-Australia Income Tax Convention ("the Convention"). 9.                  ...