The addition of the concept of Integration was added to the “buckets” (Control, Tools, Risk of Loss, Chance of Profit) because of cases at the time showing that contractors who were PSB’s were integrated into [...]
First time the courts use the 4 categories (Control, Tools, Risk of Loss, Chance of Profit) to deem someone as a PSB
Wiebe Door Services Ltd. v. Minister of National Revenue (1986) The significance in this case was that the courts summarized the “subjective checklist” from CRA and the tax code into a summary of these 4 [...]
Parliament introduced the PSB regime for circumstances where a corporation is inter-posed into what would normally constitute an employee-employer relationship.
After the CRA lost the Sazio appeal, the Canadian Government took steps to prevent a reoccurrence The Government created legislation to combat others from doing the same to avoid paying taxes; Adding Section 125(7) re [...]
Ralph Sazio restructured relationship with Hamilton Tiger Cats from Employee to a Contract with his corporation, which then employed him to provide his services Apparent goal was to shelter income in the corporation then take [...]