Does the difference between the employer and the employee when it comes to determining whether the advantage accrued primarily to the employer or the worker?

Canada (Federal), Canada

The following excerpt is from The Toronto Parking Authority v. M.N.R., 2010 TCC 193 (CanLII):

In Lowe v. Canada, [1996] 2 C.T.C. 33 (FCA), the question of whether the advantage accrued primarily to the employer or the worker was considered. In the case at bar, the primary benefit was to the TPA.

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