# LIVIA BEVILACQUA (KOA CLEANING) — COMPLETE COMPLIANCE DOSSIER **Prepared for:** Maurizio DiVito CPA (maurizio@mdivitocpa.com) **Prepared by:** Mike Ziarko, No More Chores (Alphabyte Online Inc.) **Date:** March 28, 2026 **Confidential — Legal & Tax Matter** --- ## 1. CONTRACTOR OVERVIEW | Field | Detail | |---|---| | Full Name | Livia Bevilacqua | | Business Name | KOA Cleaning | | Business Registration | BIN 1000559611 (Ontario sole prop, June 2023) | | Email | liviabevi@gmail.com | | Address on file | 21 Widmer St, Unit 3604, Toronto, ON | | HST Registration | NONE | | SIN | NOT on file | | T4A Issued | No (any year) | --- ## 2. PAYMENT HISTORY (All Years) Two sources reconciled: - **Airtable (primary):** 163 invoice records with PDF attachments. Total: **$163,851.48** - **QuickBooks Online:** Vendor ID 2349. Total: **~$147,475** (difference due to QBO using invoice amounts vs. Airtable recording actual adjusted/paid amounts including tips) The Airtable figure is the more complete record. The full invoice history CSV (163 rows) and 5 sample PDFs spanning 2022–2026 are attached as Document 09 and the sample-invoices folder. | Year | Invoices | Total Paid (CAD) | Notes | |---|---|---|---| | 2022 | 14 | $3,347.39 | First year — small jobs, weekly frequency | | 2023 | 36 | $10,197.91 | Ramp-up, 36 separate payments | | 2024 | 50 | $23,607.74 | Growing volume, weekly cadence established | | 2025 | 50 | $99,373.71 | Major year — peaked at $12K/month (May) | | 2026 YTD | 13 | $27,324.73 | Through March 2026 — on pace for $100K+ annualized | | **TOTAL** | **163** | **$163,851.48** | | **2025 monthly breakdown:** Jan $5,202 / Feb $5,190 / Mar $8,879 / Apr $8,406 / May $12,101 / Jun $8,925 / Jul $7,606 / Aug $8,002 / Sep $8,883 / Oct $9,169 / Nov $7,762 / Dec $9,249 **Payment method:** Interac e-Transfer to liviabevi@gmail.com (standard contractor payment method for all NMC subcontractors). **Nature of invoices:** Livia submitted weekly PDF invoices via Airtable. 162 of 163 invoices have PDF attachments. Invoices show flat dollar amounts with no HST line, no HST registration number, no formal invoice numbering system, and no business letterhead. This is consistent with her not being HST-registered and not operating as a formal invoicing business. --- ## 3. WORKING RELATIONSHIP & CONTRACTOR CLASSIFICATION EVIDENCE ### How work was assigned Livia was offered jobs via two methods: 1. **Automated invitation via Launch27** (NMC's booking management software) — system-generated job notifications sent to her 2. **Manual Slack messages in #livias-team** — Abigael (NMC operations coordinator) would message Livia asking if she was available for specific jobs; Livia would accept or decline Livia had full discretion to accept or decline any job. There was no set schedule or guaranteed hours. ### Evidence supporting contractor classification - Registered sole proprietorship (KOA Cleaning, BIN 1000559611) since June 2023 - Carries her own business liability insurance (Zensurance, ~$586/yr) - Manages her own team of sub-cleaners (pays workers from the Portuguese community in cash) - Has other clients outside NMC — she provided Mike access to her Booking Koala dashboard showing NMC alongside other client bookings - Passed independent background check (Google LSA via Pinkerton, June 2023) - Sets her own rates (negotiated with NMC, not dictated) - Provides her own equipment and supplies ### Evidence that may complicate classification - NMC's volume dominated her income (especially 2025: ~$92K) - Work was assigned to specific jobs with specific times/addresses (she had to show up at customer locations per booking) - No written confirmation she had other clients prior to 2023 (Booking Koala access given informally) --- ## 4. CONTRACT STATUS - Livia signed NMC's standard Independent Contractor Agreement (signed copy uploaded to Google Drive — Livia Bevilacqua compliance folder) - Key terms: classified as independent contractor, contractor share stated as HST-inclusive, no employment relationship, no guaranteed work - NMC did not collect SIN or immigration status at time of signing (not standard practice for any NMC contractor) - Agreement does not contain a residency or work authorization declaration --- ## 5. IMMIGRATION & TAX RESIDENCY STATUS ### Slack conversation — March 26, 2026 (verbatim key excerpts) The following is from #livias-team Slack channel. Mike Ziarko (U5XDTHEPQ) asked Livia (U041BQ5ENTW) directly: > **Mike:** "Are you a Canadian resident for tax purposes?" > **Livia:** "No, I am under work visa" > **Mike:** "Do you file Canadian income taxes every year?" > **Livia:** "I have not... I filed once when I was doing the marketing" > **Mike:** "Who told you that you didn't need to file Canadian taxes on a work visa?" > **Livia:** "tax advisor... just because the PR process... before were separated and now IRCC and the tax part are exchanging information" > **Mike:** "Did your tax advisor give you anything in writing confirming your non-resident status, or a Regulation 105 waiver from CRA?" > **Livia:** "no nothing" > **Livia:** "let me know I can pay the extra obligations and penalties. I dont want any problems for you at all" > **Livia:** "I ask you if can tell me with a time regarding the 15% because I will have to bring this money from my USA account slowly and BR account" (Note: Livia has funds in US and Brazilian bank accounts) > **Livia:** "I dont understand why we cant use the BN - i know lot of people that get paid using that even people with no status in canada" ### March 27, 2026 email (summary) Livia walked back the "non-resident" characterization, saying she is a "temporary resident" on a student/work visa. She is currently in Brazil (sister passed away). Her boyfriend (Canadian citizen) is sponsoring her PR via Outland spousal sponsorship process. Her accountant advised against filing Canadian taxes while PR is pending to avoid complications with IRCC. She proposed either opening a non-resident corporation or waiting for PR approval. ### Key facts established - On a work visa (type unconfirmed — could be open work permit, employer-specific, or post-graduate) - Has been living and working in Toronto since at least June 2023 (Ontario business registration date) - Has NOT filed Canadian income tax returns (confirmed by her) - Filed once previously "when doing marketing" (year unknown) - Has funds in US and Brazilian bank accounts - Accountant advised "do nothing until PR" — no documentation of this advice provided - Acknowledges potential 15% withholding obligation and offered to pay it - Has an immigration lawyer as well as a tax advisor (both unnamed) - Has NOT provided her accountant's name, contact, or any written confirmation of tax position --- ## 6. T4A HISTORY - **2022-2024:** No T4A slips issued. NMC did not have her SIN and apparently did not pursue it. - **March 2025:** Mike first requested Livia's SIN for T4A purposes. Livia responded via Slack DM (March 25, 2025) with a screenshot of CRA's T4A instructions saying that for a "Partnership or corporation," you use Box 013 (business number) instead of a SIN. Her conclusion: "so the tax goes for my company and not me." - **NMC's response to that:** No T4A was issued for 2024 (whether using BN or SIN). No T4A issued for any year to date. - **Note:** Livia's interpretation was incorrect. Box 013 applies when the recipient is a corporation or partnership. A sole proprietor still requires a SIN in Box 012 for T4A purposes. Her business number (BIN 1000559611) is a provincial registration number, not a CRA Business Number — it cannot be used on a T4A. --- ## 7. DOCUMENTS PROVIDED BY LIVIA | # | Document | Notes | |---|---|---| | 01 | KOA Cleaning sole prop registration (June 2023) | BIN 1000559611. Provincial only, not a CRA BN | | 02 | Business registration payment receipt | ServiceOntario fee ~$60 | | 03 | ONe-key account registration | Provincial online account, no tax significance | | 04 | Google LSA background check consent (June 2023) | Passed Pinkerton. Supports contractor classification | | 05 | KOA Cleaning business insurance (Sept 2025) | Zensurance, ~$586/yr. 21 Widmer St, Toronto | | 06 | Livia email March 27, 2026 | Full explanation of immigration/tax situation | | 07 | Signed IC Agreement | Uploaded to Drive by Mike, March 28, 2026 | --- ## 8. DOCUMENTS OUTSTANDING - [ ] Work permit or immigration authorization document (type of visa unconfirmed) - [ ] Written letter from tax advisor confirming residency position and advice not to file - [ ] Tax filing history (which years filed, if any) - [ ] SIN (if she has one) - [ ] Name and contact of her tax advisor - [ ] Name and contact of her immigration lawyer - [ ] Clarification on cash workers she employs — names, amounts, any CRA reporting --- ## 9. KEY RISK FLAGS (Per Maurizio DiVito's March 26, 2026 Assessment) In priority order per Maurizio's written assessment: 1. **Employee vs. contractor misclassification** — Most serious. If CRA deems Livia an employee, NMC is liable for CPP/EI/source deductions on all payments. Could far exceed Reg 105 exposure. 2. **T4A reporting failure** — No T4A slips issued 2022-2025. Required for contractor payments >$500/yr. Livia refused to provide SIN in March 2025 (citing incorrect interpretation of CRA Box 013 rules). NMC did not pursue further or issue using her business number. 3. **Work authorization** — Visa type unconfirmed. If student visa, likely 20-hr/week limit during school. Her 2025 volume ($92K) could indicate breach of work authorization. 4. **No SIN** — Required for T4A. NMC made one documented attempt (March 2025). Livia declined. 5. **Reg 105 withholding** — Livia confirmed she has not filed Canadian tax returns and claims non-resident status. NMC did not withhold 15%. Maurizio's view: factual residency (not visa status) governs — she may be a factual resident given full-time Toronto presence since 2023. 6. **HST** — Livia not HST-registered. Already coded exempt in QBO. No additional NMC exposure. --- ## 10. NMC'S CURRENT POSITION - Payments continuing (no formal freeze communicated) - Compliance concerns discussed informally on Slack March 26 only - No formal document request sent to Livia yet — awaiting Maurizio's guidance - Jerby Torres (bookkeeper) has Livia coded as exempt subcontractor in QBO - Gmail draft to Maurizio ready (with all 7 documents attached) — pending Mike's review and send - Gmail draft to Livia (document request) — drafted, not sent, pending Maurizio sign-off --- ## 11. QUESTIONS FOR MAURIZIO 1. Given Livia physically lives and works in Toronto on a work visa since at least 2023, is she a factual Canadian resident for tax purposes regardless of visa type? 2. What is NMC's exposure on T4A failure — penalty per slip and total estimated? Does our documented March 2025 attempt to collect her SIN (and her refusal) mitigate NMC's liability? 3. Does the employee vs. contractor risk apply given she has her own registration, insurance, other clients, and sub-contracts work independently? 4. She acknowledged the 15% withholding issue on Slack and offered to pay it — does this help NMC's position? 5. Should we freeze payments now, or get documents first without escalating the situation? 6. What should the formal document request to Livia say, and what is an appropriate deadline? 7. Is voluntary disclosure available for NMC on the T4A failure, and is it advisable? 8. She has funds in US and Brazilian accounts — is there any cross-border reporting obligation for NMC? 9. What is the timeline risk given she is currently in Brazil and in a PR process? --- ## 12. CONTACTS | Name | Role | Contact | |---|---|---| | Mike Ziarko | NMC Owner | mike@nomorechores.com | | Jerby Torres | Bookkeeper | jerby.torres@ledgersonline.com | | Livia Bevilacqua | Contractor | liviabevi@gmail.com | | Livia's tax advisor | Unknown — not yet named | TBD | | Livia's immigration lawyer | Unknown — not yet named | TBD | --- *This document is confidential and prepared for the purpose of obtaining legal and tax advice.*