Tax Court of Canada

Taxpayer was not cavalier about his income tax obligations

Income Tax – Administration and enforcement

Minister’s position would require taxpayers to consult with their experts and provide opinions

Income Tax – Administration and enforcement

Workers held insurable employment notwithstanding non-arm’s length relationship

Income Tax – Employment income

Taxpayer’s shareholders in Canada were making its decisions rather than its director in Netherlands

Income Tax – Residence in Canada

Taxpayers were wilfully blind to excessive valuations placed on donated software

Tax - Income tax - Tax credits

Commission income earned by life insurance broker was taxable

Tax - Income tax - Employment income