Galaxy Management Ltd. v. The Queen, 2005 DTC 1558, 2005 TCC 674 -- summary under Personal Services Business

The taxpayer, through its key employee, provided sales and purchase services to two companies engaged in the manufacture of knitted garments and the supply of textiles and yarn. If the taxpayer did not exist, the individual could reasonably be regarded be regarded only as an independent contractor rather than as an employee of the two companies. The taxpayer bore the cost of equipment, its compensation took the form of commissions, the employee received no fringe benefits from the two companies, and he was not subject to any meaningful degree of control by them. Accordingly, the taxpayer did not carry on a personal services business.