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The most that can be said is that control will no doubt always have to be considered, although it can no longer be regarded as the sole determining factor; and that factors, which may be of importance, are such matters as whether the man performing the services provides his own equipment, whether he hires his own helpers, what degree of financial risk be taken, what degree of responsibility for investment and management he has, and whether and how far he has an opportunity of profiting from sound management in the performance of his task. ...

Am I right when I state this total adjustment of $66,982,990 is the culmination of the use of the price for the transactions considered as CUP [2] by Revenue Canada and which we looked at under Tabs 5, 6, 7, 8 and 9 of Binder 9?                 ...

Normally, one would have referred to the provisions under which the appellant could be considered a UN employee. ...

They confirm that the "tax loss" aspect was clearly a factor considered when the condo was purchased. ...

Whether the worker has the power to hire people to do the work or must perform the work himself must also be considered. ...

(e)         employment in Canada by the government of a country other than Canada or of any political subdivision of the other country if the employing government consents; [8]      Section 3 of the Employment Insurance Regulations ("the Regulations ") states the following in this regard: 3(1)       Employment in Canada by the government of a country other than Canada or of any political subdivision of that other country, or by an international organization, that would, except for paragraphs 5(2)(d) and (e) of the Act, be insurable employment, may be included in insurable employment if the employing government or the international organization, as the case may be, consents in writing to its inclusion. (2)         Where a consent has been given pursuant to the Unemployment Insurance Regulations, as they read immediately before June 30, 1996, and has not been revoked, it shall be considered to be a consent referred to in subsection (1). [9]      Paragraph 5(2)(d) of the Act provides that insurable employment does not include employment in Canada by the government of a country other than Canada. ...

The entire investment picture should be considered (Smith). 12.            ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

[emphasis added] DAILY ROUTINE [7]            On typical workdays during 1996 and 1997 the Appellant drove the Company car from his Dartmouth residence and travelled two kilometres to his Dartmouth office or 2.5 kilometres from his residence to his infant daughter's daycare and then on to work, all of which is considered by the Appellant to be personal travel. [8]            The Appellant drove the Company car extensively beyond the Dartmouth office for work-related purposes for the Keating Group of Companies. ...

., [1960] 3 All E.R. 420 the Privy Council considered the case of a pilot who controlled a corporation and who appointed himself the chief pilot at a salary arranged by him. ...