Précis: This is a lengthy (217 paragraphs), erudite and factually complex decision involving 218 workers. The taxpayer, AE Hospitality Ltd. (AE), provided staff to two catering companies owned, in whole or in part, by related individuals. The Minister found that all of the employees were engaged in insurable and pensionable employment in 2016. The Court, after an extensive analysis agreed with the Minister’s position (without the necessity for recourse to the Minister’s alternative “placement agency” argument). An appeal in respect of two individuals in 2015 was allowed in part.
AE Hospitality Ltd. v. R. – TCC: staff provided to catering companies were engaged in insurable/pensionable employmentREAD MORE »