How have CCRA employees and the CCRA appeal process been handled in the context of an arm's length working relationship?

Of course, hundreds of hours of work on the part of CCRA employees and the effort and expense occasioned by the entire appeal process would not have been necessary had Nagra taken the time and effort to document - in a clear and concise manner - every significant aspect of the working relationship between himself and his related workers, particularly the manner of payment. Bank charges are not so costly that cheques could not have been issued - one to the other - in payment of rent and for payment of wages. If cash advances were paid from time to time, that practice – per se – is not extraordinary, provided appropriate documentation exists in respect of these transactions. In the case of Barbara Docherty v. M.N.R. ‑ [2000] T.C.J. No. 690 - dated October 6, 2000, I commented as follows: The template to be utilized in making a comparison with arm's length working relationships does not require a perfect match. That is recognized within the language of the legislation because it refers to a "substantially similar contract of employment". Any time the parties are related to each other within the meaning of the relevant legislation, there will be idiosyncrasies arising from the working relationship, especially if the spouse is the sole employee or perhaps a member of a small staff. However, the object is not to disqualify these people from participating in the national employment insurance scheme provided certain conditions have been met. To do so without valid reasons is inequitable and contrary to the intent of the legislation.