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    TaxKilnCanadian tax guidance

    Employee vs independent contractor

    Misclassification is the most common CRA enforcement target in self-employment. Whether you are an employee or independent contractor is a question of fact, not contractual labels — and getting it wrong creates back-taxes, penalties, and (if you contract through a corporation) the Personal Services Business trap.

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    1. The Wiebe Door four-factor test

    From Wiebe Door Services Ltd v MNR [1986] and confirmed in 671122 Ontario Ltd v Sagaz Industries [2001 SCC 59]: courts weigh four factors holistically.

    • Control — who directs what, when, where, and how the work is done?
    • Tools and equipment — who supplies them?
    • Chance of profit / risk of loss — does the worker bear entrepreneurial risk?
    • Integration — is the work an integral part of the payer's business?

    2. Connor Homes intention overlay

    1392644 Ontario Inc (Connor Homes) v MNR [2013 FCA 85] added a two-step approach: (1) the common intent of the parties at contract formation; (2) whether the objective facts (Wiebe Door factors) support that intent. Intention matters but cannot override clearly inconsistent facts.

    3. The PSB trap at $120k — three-column comparison

    Item ($120k gross)EmployeeTrue contractorPSB (CCPC)
    Federal corp raten/a9% SBD33% (no SBD)
    Deductible expenseslimited T2200full T2125 / corpsalary + benefits only (s.18(1)(p))
    CPP / EIboth halves via employerCPP both halves; no EICPP via salary
    Effective total tax~25–28%~15–25% deferred~45%+ (no integration)

    A Personal Services Business (s. 125(7)) is a CCPC where the worker would be an employee of the payer but for the corporation. Consequence: no SBD, restricted deductions (s. 18(1)(p)), additional 5% federal tax — total effective ~33% corporate rate, then dividend tax on extraction.

    4. CRA ruling request — Form CPT1

    Either worker or payer can request a binding CRA determination via Form CPT1. Used carefully it provides certainty; used carelessly it triggers reassessment.

    5. Industry-specific enforcement

    • Construction — CIS-style scrutiny on subcontractor classification
    • IT — long-term single-client contractors prime PSB targets
    • Beauty / hair — chair-rental documentation review
    • Trucking — owner-operator vs employee driver

    6. Three worked examples

    Example A — clear contractor: graphic designer with five clients, owns laptop and software, invoices per project, works from home, declines additional clients to manage workload — contractor.

    Example B — disguised employee: "contractor" working 9-5 at client's office for two years, supplied laptop and email, single client, paid weekly — employee in substance, despite contract.

    Example C — PSB risk: developer incorporates, contracts solely to former employer at $130/hour, on-site, no other clients — meets PSB definition; corporate structure loses SBD and deductions.

    7. Misclassification consequences

    For the payer: back CPP/EI both halves, interest, gross negligence penalty (50% where applicable). For the worker: reassessment of business expenses, CPP reclassification, potential loss of HST collection treatment.

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