Hi Maurizio,

Thank you for the thorough assessment. It was extremely helpful and I've been working through it since you sent it. I want to bring you up to speed on some new information that came in after your email, share the full compliance dossier I've now compiled, and then ask a few follow-up questions based on your recommendations.

What's changed since your email:

On March 26, Livia sent me a detailed email clarifying her position. Key points:

• She confirms she is a temporary resident on a study/work visa (not a non-resident as she initially characterized herself — I think she was using the wrong terminology and may have been getting confused advice)
• She says she has an accountant who advised her not to file taxes because CRA had no prior records and the accountant was concerned it could complicate her PR application. So there's a professional involved who gave her that direction.
• She is currently in Brazil and has stayed longer than planned following the passing of her sister. She is an only child now and needed to be with family. Relevant context for setting any document deadline.
• She proposed two paths forward for 2026: (A) open a new corporation now and move forward, or (B) wait until her PR is approved and then incorporate with an HST number. I have not responded to her yet and wanted your input before I do.
• She has no SIN on file with me — confirmed. She has not provided one to date despite a request in March 2025.

I have now compiled a complete compliance dossier on Livia. It includes her full invoice history (163 invoices, $163,851 total — more complete than the QBO figure I gave you), 5 sample invoice PDFs spanning 2022 to 2026, Booking Koala analysis showing she operates her own sub-contracting business with approximately 15 cleaners and 15 to 18 private clients, and relevant Slack correspondence. It is available here:

Google Drive — Livia Bevilacqua Compliance File

Follow-up questions based on your recommendations:

1. Payments freeze — completed work: You recommended freezing payments immediately, and I agree. I have not paid her this week's work yet. She completed approximately 10 jobs this week before going to Brazil, worth roughly $1,969 in contractor fees. Does the freeze apply to work already completed, or can I pay for completed jobs while gathering documents? I want to handle this carefully so I don't create a separate dispute.
2. Work permit type: You flagged the open vs. employer-specific permit distinction as critical. She claims to be on a study permit with work authorization, but has not provided documentation. If she has a study permit, she is generally allowed to work off-campus up to 20 hours per week during school. Is that sufficient authorization for the volume of work she has been doing (14 jobs per week, approximately $2,100 per week in 2025/2026)? And does this affect NMC's exposure?
3. Her two proposed paths (new corp now vs. wait for PR): Livia proposed either incorporating a new company now or waiting until her PR comes through. Is either of these a viable path forward, and does pursuing either option affect how we handle the historical compliance issues?
4. Her accountant: There is a professional who apparently advised her against filing. Does that change the picture at all in terms of penalty mitigation, or does that only help her, not NMC?
5. T4A and voluntary disclosure: You recommended against rushing into voluntary disclosure until the underlying facts are established. Now that I have the fuller picture (resident contractor, no T4As issued, no SIN, $163K paid), does your view on VD change? Is this something we should be moving toward, or still wait?
6. Slack acknowledgment: In an earlier conversation, Livia acknowledged the 15% withholding issue and offered to cover it herself. I have that in writing. Does that acknowledgment carry any weight with CRA, and should we document it formally as part of the file?
7. Her bookings going forward: She has approximately 14 active jobs per week assigned to her in my booking system. While this is being resolved, do I need to reassign those jobs to other contractors, or is there a way to continue using her as a subcontractor in the meantime? What is the risk of continuing to assign work to her before we have her documentation?
8. Longer-term — employee conversion: Separately from the compliance cleanup, I have been thinking about the longer-term relationship with Livia. She is my highest-volume, most reliable contractor. Once her immigration status is resolved, I would be open to converting her to a formal employee role, potentially as an operations manager. As you think through the misclassification risk, are there steps I should be taking now to document the relationship differently or adjust the working arrangement to support a cleaner transition later if I go that route?
9. Document request letter: Would your office be able to draft the formal document request to send to Livia, given the legal and tax sensitivity? I want to make sure it is worded correctly and does not inadvertently create additional exposure.

Happy to jump on a call to go through any of this. Let me know what works.

Thanks,
Mike Ziarko
No More Chores
647-490-2523

Replying to your email of March 26, 2026 — RE: Urgent: Non-Resident Contractor Issue + HST Filing Update