Policar v. M.N.R.
A-195-98
Desjardins J.A.
22/2/99
4 pp.
Application for judicial review of Tax Court of Canada decision on ground erred in interpretation of Unemployment Insurance Regulations, s. 14(f)(i) and Agreement between Canada and United States respecting unemployment insurance, Art. IV(a)(2)(ii)-Payer American company with corporate headquarters in State of Utah in United States-Applicant, resident of Quebec, hired as sales representative under contract of service-Art. IV of Agreement seeks to establish where employee's services for employer performed-Applicant's services performed in territory covered by contract, including Quebec, not in Utah-Although place from which applicant's services directed or controlled not localized in Quebec but in Utah, applicant's residence in jurisdiction where some of services performed, namely in Quebec-Applicant's entire services in Canada and American Upper North East accordingly insured under Unemployment Insurance Act in force in Canada-Application allowed-Unemployment Insurance Regulations, C.R.C., c. 1576, s. 14(f)(i)-Agreement between Canada and United States of America respecting Unemployment Insurance, April 12, 1942, [1942] Can. T.S. No. 4, Art. iv-Unemployment Insurance Act, R.S.C., 1985, c. U-1.