The Alberta Motor Association (AMA) carried on a business of training and providing instruction to individuals who wanted to obtain vehicle operators licenses. Mr. Snell had an arrangement with AMA to provide such instruction. AMA had treated Mr. Snell as an independent contractor from 2020 to 2022. Mr. Snell was claiming that he was an employee of the Alberta Motor Association in 2022.

Other information about the arrangement is as follows: Mr. Snell was hired as a driving instructor Mr. Snell entered into a written contract with AMA stating that Mr. Snell was a contractor and not an employee Mr. Snell had been under contract with AMA since 2020 Mr. Snell earned a set fee of $26 per hour Mr. Snell also received fees for new bookings, student home pickups, and a fuel subsidy Mr. Snell invoiced AMA Mr. Snell did not receive any employee benefits such as health, dental, or vacation pay AMA did not guarantee Mr. Snell a minimum amount of pay AMAs hours of operation were from 8:00 a.m. to 5:00 p.m. Monday to Saturday Mr. Snell set his own schedule of hours and days of work Mr. Snell could work anytime between 8:00 a.m. and 10:00 p.m. Monday to Sunday Mr. Snell did not have a set minimum number of hours of work required Mr. Snell kept a record of his hours worked AMA provided Mr. Snell with the names of the students Mr. Snell contacted the students and scheduled the road instruction AMA provided Mr. Snell with an in-vehicle lesson guide Mr. Snell chose the routes for the lessons Mr. Snell was able to hire his own helper for administrative tasks Mr. Snell provided the major tool, which was the vehicle AMA provided vehicle signage, mirrors, traffic cones, and an emergency brake Mr. Snell paid for the installation and removal of the emergency brake provided by AMA Mr. Snell incurred operating expenses, including vehicle expenses, liability insurance, and a driver training endorsement Mr. Snells vehicle expenses included insurance, maintenance, and fuel AMAs intention was that Mr. Snell was a contractor and not an employee Mr. Snell had operated his own taxi business since 2004 Mr. Snell maintained his own business books and records Mr. Snell declared business income and business expenses on his 2020, 2021, and 2022 income tax returns

Required: Write a short memo to Mr. Snell about whether he would be viewed as an employee of the Alberta Motor Association or, alternatively, an independent contractor by the CRA. List all of the factors that should be considered in reaching a conclusion.