HomeMy WebLinkAbout1999-1773.GroupGrievance.01-04-02.Decision
o NTARI 0 EMPLOYES DE LA COL'RONNE
CROWN EAIPL0 YEES DE L "ONTARIO
. . GRIEVANCE COMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 600 TORONTO ON M5G 128 TELEPHONElTELEPHONE, (416) 326-1388
180 RUE DUNDAS OUEST BUREAU 600 TORONTO (ON) M5G 128 FACSIMILElTELECOPIE. (416) 326-1396
GSB#1773/99, 2066/99, 2082/99
OPSEU#00B035,00E045, 00E052
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontano PublIc ServIce Employees Dmon
(Group Grievance Anten et aI., Group Grievance Lau, et al , Brar)
Gnevor
- and -
The Crown m RIght of Ontano
(Mimsm ofFmance)
Employer
BEFORE Michael V Watters Vice-ChaIT
FOR THE E. Holmes, Counsel
GRIEVOR Ryder Wnght, Blair & Doyle
BarrIsters and SolIcItors
FOR THE M. Nixon, Counsel
EMPLOYER S Patterson, Counsel
Legal ServIces Branch
Management Board Secretanat
HEARING June 1,2000 November 9 2000 November 15 2000
November 29 2000 December 19 2000 and
March 1 2001
DECISION
The grievance, dated August 31, 1999, which led to this proceeding, was filed on
behalf of a group of twenty-four (24) Investigators working in the Special Investigations Branch
in the Tax Revenue Division of the Ministry of Finance The grievance reads, in part:
"STATEMENT OF GRIEVANCE
We grieve that we are not being compensated appropriately in accordance
with the collective agreement(s) including, but not limited to, article, ADM 16 1 and the
Salary Schedule for the Administrative Category Bargaining Agreement. We are
presently paid at the Investigator F 0 5 level We should have been included in the
classification adjustment for the Administrative Category for the new Tax Auditor
classification standards
SETTLEMENT DESIRED
We the Investigators F 0 5, be included in the classification adjustment for the
Administrative Category for the Tax Auditors classification with full retroactivity and
interest on all monies owed effective January 1 st, 1999 "
(Exhibit #2, Tab #1)
Grievances were subsequently filed on behalf of a number of other Investigators These
grievors, in effect, asked to be included in the group grievance reproduced above
A number of classification adjustments in respect of the Administrative Bargaining Unit
Collective Agreement were agreed to during the negotiations for the collective agreement
covering the period January 1, 1999 to December 31 , 2001 The adjustments are contained
within a Letter of Understanding found between pages 188 and 191 of the collective
agreement. The material part of this Letter of Understanding provides
2
ADM
Tax Auditors
The Employer shall develop new Tax Auditor series and class standards for the
positions of Tax Auditors in the Ministry of Finance (currently they are in the Financial
Officer series, except for 4 employees in the Tax Auditor series, level 3)
The new ranges shall have the following minima and maxima
Min Max % Increase
Over F01-5
Tax Auditor 1 37,595 43,313 517
T ax Auditor 2 41,910 48,314 213
T ax Auditor 3 47,457 55,919 690
T ax Auditor 4 51,910 62,565 664
T ax Auditor 5 58,318 70,515 11 19
Steps will move by same percentages, and employees will remain
at their current step
The 1999 general wage increase will be applied to the above ranges
ADM
I nspecto rs/l nvestig ato rs
It is agreed that the employer will undertake a review of the following classes,
with a view to updating! revising class standards and establishing a new pay
framework for the identified investigator classes
The pay framework shall have 3 to 4 salary ranges
The minimum and maximum of the two highest ranges shall
be as follows
2nd highest salary range
minimum $1,000 per week maximum $1,158 per week
highest salary range
minimum $1,080 per week maximum $1,242 per week
The lower salary ranges as well as steps between the minimum and the maximum shall
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be established upon completion of the new class standards
Highest salary range Populations
Environmental Officer
5 investigator jobs 66 (approx.)
Fire Services Investigator 2 10
2nd highest salary range
Employment Standards Auditor 2 104
Environmental Officer
4 investigator jobs 195 (approx.)
Fire Services Investigator 1 32
Human Rights Officer 2 45
Occupational Health &
Safety Inspector 2 202
The lower salary range(s)
Employment Standards Auditor 1 29
Public Health Inspector 3 1
Safety I nstruction Officer 2 7
Safety I nstruction Officer 3 3
Field Worker 1, Homes for
special care 4
TOTAL 689
Employees, whose current salaries are below the minimum of the new range for
their revised class, shall move to the new minimum
Employees whose current salaries are equal to or between the minimum and
maximum of the new range for their revised class shall move to the step that is closest
to but not less than their existing rate of pay
Employees shall retain their current hours of work schedule and overtime entitlements
The 1999 general wage increase will be applied to the above ranges
4
The Employer agrees there will be no wage decrease as a result of the
updating/revising class standards and establishing a new pay framework for the identified
investigator classes
The thrust of all of the grievances now before the Grievance Settlement Board is that
the Investigators should have received the classification adjustments provided to Tax Auditors
pursuant to this Letter of Understanding
On the first day of hearing, counsel for the Employer raised three (3) preliminary
issues, which may be summarized as follows
1 The grievors, in substance, contest their classification as Financial Officers and
claim the benefit of the revised salary ranges applicable to employees falling under
the new Tax Auditor series and class standards It was counsel's submission that I
lack jurisdiction to hear such a complaint, and to provide a remedy in respect of
same, given the prohibitions contained in sections 51 and 52 of the Crown
Employees Collective Barqaininq Act, 1993 These sections, inter alia, prohibit the
Grievance Settlement Board from ordering the creation of a new classification or the
alteration of an existing classification From the perspective of the Employer, the
grievors request this form of relief;
2. The language of the Letter of Understanding is clear in the sense that it is directed
towards Tax Auditors and not Investigators Counsel for the Employer submitted
that, in effect, the Union is asking for an amendment to the collective agreement and
that I lack jurisdiction to award such a remedy It was suggested that the Union
should pursue its concerns through either collective bargaining or resort to the Joint
System Subcommittee, and
3 As the language of the Letter of Understanding is clear and unambiguous, extrinsic
evidence should not be received or relied on in aid of interpretation
5
The Employer cited the following authorities in support of its position OPSEU (Aitken
et al) and The Crown in Riqht of Ontario (Ministry of Health), GSB No 678/87 (Gorsky),
OPSEU (Rosamond) and The Crown in Right of Ontario (Ministry of Citizenship, Culture and
Recreation), GSB No 2086/96 (Leighton), OPSEU (Lyons) and The Crown in Right of Ontario
(Ministry of Health), GSB No 2289/93 (Petryshen), International Nickel Co. of Canada Ltd.
and United Steelworkers (1974), 5 L.A.C (2d) 381 (Weatherill), OPSEU (Craiq, Grimes) and
The Crown in Riqht of Ontario (Ministry of Transportation), GSB No 2662/91, 2711/91
(Dissanayake)
Submissions were presented by counsel for both parties with respect to the
preliminary issues Following the submissions and after discussion between counsel and this
Vice-Chair, it was agreed that the case would proceed as follows (i) the issue to be
addressed would be restricted to whether the grievors were intended to be included within, or
captured by, the Letter of Understanding, (ii) extrinsic evidence would be received relating to
what occurred at the bargaining table, the parties' intentions thereat, what they had in their
minds at the time, and the context of the negotiations, (iii) the decision on the ultimate
admissibility and effect of such evidence would be reserved, and (iv) the parties would avoid
taking a "classification approach" to the presentation of their respective cases, that is, they
would not focus on a comparison of job duties With respect to point (iv), the parties were
informed that, in my judgment, I lack the jurisdiction to proceed with a classification case or to
award a classification remedy I appreciate the efforts of counsel for their attempts to comply
with this agreement over the course of the six (6) days of hearings
6
A dispute relating to the disclosure of documents was addressed on the second and
third day of hearings The documents in issue were itemized as follows in a letter dated May
24, 2000 from Mr E Holmes, counsel for the Union, to Ms M Nixon, counsel for the
Employer"
"1 All documents prepared with regard to the new Tax Auditor
series of classifications (We understand that Marilyn
Masson coordinated the research)
2 All documents prepared by or for Marion Crane, in response
to our representations We understand that an initial report
was prepared, and a revised report includ ing fact finding
into Charter of Rights decisions such as Jarvis
3 Documentation to Marion Crane requesting that her initial
report be revised
4 Any and all correspondence concerning
- the Tax Auditor classification
- the classification of the investigators
between employees and or appointees in
- the Ministry of Finance
- Management Board
- the Ministry of Finance and Management Board
including Roy Lawrie, Dario Savio, Marion Crane and Marilyn Mason
5 Any and all records concerning the reclassification of the
auditors in the Financial Officer classification series to the
Tax Auditor classification series, and the exclusion of the
Financial Officers in the Special Investigations Branch from
the reclassification, including records of Human Resources
Branch and the Tax Revenue Division
6 Any and all records concerning your letter dated January 17,
2000 which denied the investigators' grievance at Stage 2 "
(Exhibit #3, Tab #1)
By way of clarification, it appears that the material prepared by Ms Marion Crane, as
referenced in paragraph #2 of the request, was prepared as a fact finding report for the
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benefit of Mr E C Farragher, the Employer's Stage 2 designee I was informed that the initial
report was destroyed and that the only document in existence was the final report. Similarly,
the documents referenced in paragraph #6, relate to information which may have contributed
to the denial of the grievance at Stage 2 Lastly, I note that ore of the items requested under
paragraph #4 was a draft MB20 which was originally prepared for submission to Cabinet in
support of a wage increase for Tax Auditors I was left with the impression that the document
was never formalized and presented to Cabinet as the Employer opted to address the issue
through collective bargaining
The Employer opposed the request for disclosure Generally, it was asserted that
much of the material requested was irrelevant to the central issues of the case This assertion
was premised on two (2) grounds, firstly, many of the documents related to classifications,
and, secondly, they were generated after the set of negotiations material to this dispute
Counsel for the Employer argued, therefore, that the documents would not assist in the
resolution of the issue identified and agreed to by the parties on the first day of hearing
Counsel further submitted that the documents requested in paragraphs #2 and #6 were
privileged as they were prepared for purposes of Stage 2 of the grievance procedure In the
alternative, it was submitted that such documents were protected from disclosure by litigation
privilege Finally, a claim to Crown privilege was advanced in respect of the draft MB20
document.
8
The Employer relied on the following authorities in support of its position Re
International Association Of Fire Fiqhters, Local 626, Borouqh Of Scarborouqh (1972), 24
L.A.C 78 (Shime), Re Liffey Custom Coatings Inc. and London and District Service Workers'
Union, Local 220 (1996), 59 L.A.C (4th) 7 (Williamson), Re Brewers Retaillnc and United
Brewers Warehousinq Workers Provincial Board, U.F.C.W., Local 326w (1998),71 L.A.C
(4th) 28 (Aggarwal), Re Ontario (Manaqement Board of Cabinet) (1998) 0 L R D No 1598
(Surdykowski)
In response, counsel for the Union argued that he was entitled to full disclosure under
articles 22 14 4 and 22 14 5 of the collective agreement which read
22.144 The parties agree that principles of full disclosure of issues
in dispute as alleged by a grievance advanced by the Union
on behalf of a member or members, or the Union itself, and
full disclosure of facts relied upon by management in a
decision that is subject to a grievance, are key elements in
amicable and expeditious dispute resolution processes
22.145 The parties agree that at the earliest stage of the grievance
procedure, either party upon request is entitled to receive
from the other, full disclosure
Generally, it was the position of the Union that the documents requested were arguably
relevant and should, accordingly, be disclosed Counsel acknowledged that an order for
disclosure did not mean the documents would automatically be admitted when formally
tendered as evidence It was the further position of the Union that the Employer had failed to
support non-disclosure on any of the privileges claimed With respect to the issue of litigation
privilege, he asserted that the documents were not prepared for the "dominant purpose" of
9
litigation On his analysis, litigation was not contemplated at the time the documents were
produced With respect to Crown privilege, counsel noted that the claim had not been made
by the Minister, as required He suggested that such claim was merely premised on the
general assertions of opposing counsel It was argued the Employer failed to demonstrate
that the public interest it asserted in support of non-disclosure outweighed the interest of
having a fully informed decision Counsel for the Union asked that I inspect the MB20 before
ruling on the claim to Crown privilege
The Union relied on the following authorities in support of its position OPSEU
(Hyland) and The Crown in Right of Ontario (Ministry of Correctional Services), GSB No
1062/89 (Ratushny), Re Laurentian Hospital and Ontario Nurses' Association (1997), 67
L.A.C (4th) 289 (Pineau), OPSEU (Kumor) and The Crown in Riqht of Ontario (Ministry of the
Solicitor General and Correctional Services), GSB No 1698/96 (Finley), Re Government of
The Province of British Columbia and British Columbia Government Employees' Union
(1979), 22 L.A.C (2d) 382 (Levey), Re The Crown in Right of Ontario (Ministry of Correctional
Services) and OPSEU (Kniqht) (1994), 39 L.A.C (4th) 205 (Kirkwood), Wauqh v British
Railways Board, (1979) 2 All E R 1169 (H L.), Re Toronto Star Newspapers Ltd and
Southern Ontario Newspaper Guild, Local 87 (1993), 33 L.A.C (4th) 174 (Springate), Re
Columbia Bitulithic Ltd and Construction and General Workers' Union, Local 602 (1996), 58
L.A.C (4th) 9 (Taylor)
Following the submissions, this Vice-Chairperson made the following ruling
10
"I have considered all of the submissions presented last day and
today with respect to what documents should be disclosed to the Union I
have also considered the instructions that I gave on June 1, 2000 relating
to the approach I intend to take to this case More specifically, the issue
before me is whether the grievors were intended to be included in, or
captured by, the Letter of Understanding agreed to in March, 1999 The
issue is not whether they are improperly classified as Financial Officers
Clearly, at this time, I lack the jurisdiction to award a classification
remedy
My ruling on the production request is as follows
1 I order production of the documents requested in paragraph
numbers 1,4 and 5 of Mr Holmes' letter of May 24,2000 subject
to the following conditions
(i) the Draft M B20 document, unless the Employer agrees to
disclose it directly to the Union, is to be first provided to this Vice-
Chair-person for my review I will then decide whether it should be
released I elect to take this intermediate step as I remain
somewhat uncertain as to the nature and content of such a
document and whether it is something that merits exclusion on the
ground of Crown Privilege,
(ii) the material disclosed is to be used for purposes of this case only
and is otherwise to be treated as confidential by the Union, its
counsel, advisors and witnesses,
(iii) this ruling will not preclude further argument as to whether the
material disclosed should be admitted into evidence To be
clear, the fact such material is now ordered disclosed is no
guarantee that it will be received in evidence at some later point
in this proceeding
Generally, I have been persuaded that the documents referenced in paragraph
numbers 1, 4 and 5, which I have ordered be disclosed, are arguably relevant to the issue as
framed I have not been persuaded, subject to the reservation on the Draft MB20, that the
privileges advanced by the Employer support the nOrl-disclosure sought.
2 I decline to order production of the documents prepared by Ms
Crane relating to the Stage 2 meeting Ultimately, I have not been
satisfied as to the arguable relevance of such documents I note
11
in this regard, that the grievors did receive a somewhat detailed
Stage 2 reply from Mr EC Farragher, Director, Human
Resources Branch on January 17, 2000 (Exhibit #7) "
After the receipt of additional submissions, it was further ordered that the cut-off date for
purposes of disclosure was January 17, 2000
I note at this juncture that it was unnecessary to make an order with respect to
paragraph #3, as there was no such document in existence The M B20 document was never
subsequently presented for my inspection I was left with the impression that it was given
directly to the Union
Mr Steve Nield and Mr Peter Coates presented evidence on behalf of the Union Mr
Nield is a Regional Health and Safety Officer with the Ministry of Labour He served as Vice-
Chair for the Administrative Category Bargaining Team during the last round of bargaining,
and was, in this capacity, directly involved in the negotiation of the Letter of Understanding
material to this case Mr Nield was one (1) of the group of individuals who signed the
document on behalf of the Union Mr Coates is an Investigator in the Special Investigations
Branch He commenced employment with the Employer in 1982 and has been classified as a
Financial Officer 5 (F 0 5) since 1994 M r Coates is one (1) of the group of grievors in this
proceeding
Mr E C Farragher, Ms Helen Ecker, Ms Stephanie Crawford, Ms Marilyn Mason and
Mr Rocco Stangarone gave evidence as witnesses for the Employer Mr Farragher is the
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Director, Human Resources Branch of the Ministry of Firance He has occupied the position
for more than twenty (20) years He is responsible for the overall human resources function
including staffing, compensation, training and development, classification, human resources
planning and quality services Mr Farragher participated at the central table during the last
round of negotiations Ms Ecker is a Labour Relations Consultant in the Human Resources
Branch She has been in the position for one (1) year Ms Ecker was previously a Human
Resources Consultant in the same Branch for nine (9) years Ms Crawford is the Manager of
Staff Relations for the Ministry of the Solicitor General and Correctional Services She
previously worked in Corporate Staff Relations at the Management Board Secretariat. Ms
Crawford was the Employer's lead spokesperson at the Administrative Bargaining Unit table
during the last round of bargaining with the Union Ms Mason is the Director of the
Collections-Compliance Branch in the Tax Revenue Division She previously worked as
Director of the Tax Integrity Program of which more is said below M r Stangarone has been
the Senior Manager, Investigations since 1988 In this position, he manages a group of
Investigators who investigate suspected tax evasion under the Gasoline Tax Act, the Fuel Tax
Act and the Tobacco Tax Act Prior to 1988, Mr Stangarone worked as a Group Leader and
as an Investigator
Until the decision in OPSEU (Alton et al ), GSB No 1580/86, 1594/86 (Dissanayake),
Investigators in the Special Investigations Branch were classified at the Financial Officer 4
level The decision dated July 4, 1990 ordered that they be reclassified to the Financial
Officer 5 level as such classification represented "the clear best fit" in respect of the duties
13
and responsibilities of the Investigator position The decision describes the work of the
I nvestigator as follows
"When the evidence is reviewed, it is clear that "full scale
investigation of suspected fraud" is exactly what the grievors do, in
a large number of their assignments These investigations require
two skills (1) Financial and accounting (2) Investigation Mr Cyril
Pothier, Manager of Operations at the relevant time, testified that
the grievors' positions are unique because they do accounting
functions as well as "police work" He testified that the grievors'
work breaks down "fifty/fifty" between accounting work and
i nvesti gati 0 n w ork. ------------------------------------------------------------------
--------------------------------------------------------------------
The evidence indicates that prior to the Special Investigations
Branch taking over these investigations, various police forces
conducted them While the police officers performed the
investigative aspects or the police work, a firm of forensic
accountants was retained to carry out the financial and accounting
aspects of the investigation The grievors perform both aspects
This evidence highlights the importance of the grievors, "police
work" such as interrogating witnesses, preparing and executing
search warrants and summonses, instructing the crown prosecutor
and testifying as crown witness As already noted, Mr Pothier's
own opinion was that the grievors' investigative skill and expertise
are as important as their skill and expertise in the accounting and
financial fields I n our considered view, the FO-4 class standard
does not recognize the significance of the grievors' investigative
functions, but focuses predominantly on the finance and accounting
aspects On the other hand, the FO-5 class standard captures the
dual role of the grievors "
(Exhibit #2, Tab #12,
pages 12-14)
The "dual role" of the Investigators, as referenced in the above excerpt from Alton et
~, is captured in the current Position Specification and Class Allocation form The purpose
of the position is described therein as
"To conduct detailed investigations and in-depth audits involving
possible fraud concerning the evasion of taxes or obtainment of
grants or subsidies under all statutes administered by the Tax
14
Revenue Division To participate in the prosecution of cases
against violators identified by these investigations and audits"
(Exhibit #2, Tab #4)
Until the mid-1980's, there existed a three (3) level Tax Auditor classification series At
or around that time, an initiative was taken by the Employer to shift all but a small number of
positions in this series to the Financial Officer classification series All of the positions so
moved were classified as atypical within the Financial Officer series I was advised that this
change occurred because the Employer wished to improve the compensation paid to Tax
Auditors, in order to promote recruitment and recognize increased complexity in the work, but
was unable to achieve the objective within the confines of the Tax Auditor series One (1) of
the positions affected by this development was the Senior Corporations Tax Auditor Field
The Position Specification and Class Allocation form for this position, which was classified as
Financial Officer 5 (Atypical), describes the purpose of the position as follows
"As a senior auditor is responsible for carrying out a group of
audits assigned to him/her by his/her supervisor in order to
ascertain compliance with the Corporations Tax Act, the Income
Tax Act (Canada) and Mining Tax Act. Document areas of non-
compliance for reassessment. Depending on the size and/or
complexity of the audit, (s)he may be assisted by a team(s) of
auditors working on the same file, and/or a group of alditors
working independently on different audits, under the guidance of
his/her superior(s) allocate work to team and guide their actions
Provide assistance re the technical aspects and/or performance of
the unit."
(Exhibit #2, Tab #5)
Bargaining for the current collective agreement commenced in early 1998 and
continued for approximately one (1) year The Employer presented its proposal in respect of
the classification adjustments here in issue during the afternoon of March 17, 1999 The
15
parties at that juncture were facing a strike deadline The proposal, as presented, was
identical in form and content to the Letter of Understanding ultimately incorporated into the
collective agreement. Mr Nield recalled that the Employer was disinclined to discuss any
modifications to the proposal In his words, it was presented as a "take it or leave it" offer
The proposal was accepted in the early morning of March 18, 1999
Mr Nield testified that the Union was presented with a strip list at the outset of
bargaining The list, generated from Corpay data, shows the number of employees actively
working in classifications within the Administrative Bargaining Category More specifically, it
identifies the number of persons employed in the Financial Officer and Tax Auditor
classifications The strip list was filed as part of Exhibit #3, Tab #8
Mr Nield stated that when the classification adjustments were tabled, the Union
representatives resorted to the strip list to determine how many employees would be affected. It
was his evidence that the review of the strip list indicated a total of nine hundred and ninety-eight
(998) employees would be impacted. This figure was comprised of nine hundred and ninety-four
(994) employees working in levels one (1) to five (5) of the Financial Officer series and four (4)
employees working in level three (3) of the Tax Auditor series Mr Nield asserted that the strip list
was the sole means available for the Union to assess or verify the number of employees who would
benefit from the adjustments proposed. He was unable to say whether the Employer
representatives at the table were similarly working from a strip list.
16
Mr Nield testified that during the discussion surrounding the classification adjustment,
the Union conveyed its understanding to the Employer that nine hundred and ninety-eight
(998) employees would be affected It was the thrust of his evidence that the Employer did not
dispute this understanding In cross-examination, Mr Nield was asked if the Union ever
specifically inquired as to whether the figure of nine hundred and ninety-eight (998) was an
accurate assessment of the impact of the classification adjustment in respect of Tax Auditors
Mr Nield replied that he could not say with certainty He maintained, however, that such
number was on the table and that there was no dispute forthcoming from the Employer Mr
Nield denied the suggestion that the Employer's representatives at the table limited the
proposal to Financial Officers who performed tax audits as part of their job He asserted that
if such a statement had been made, the Union would have asked for a more specific figure in
terms of the number of affected employees
Mr Nield acknowledged that there was no specific discussion during the negotiations
about the Investigators or the functions of other employees classified as Financial Officers
He seemed to suggest that the Union focused more on classifications than positions, as its
primary source of information was the strip list. Mr Nield did not know at the time that there
were positions with the titles of I nvestigator and Tax Auditor He stated that he was aware that
some employees within the Financial Officer series performed tax audit functions Mr Nield
further stated 1I1at there was no discussion about excluding anyone from the new series He
asserted, on at least two (2) occasions, that the exchange between the parties focused on the
17
entire classification It is clear that there were no Financial Officers on the Union's negotiating
team Additionally, the team did not contact any Financial Officers to discuss the Employer's
proposal before it was agreed to
In summary, it was the Union's understanding that all of the employees within the
Financial Officer classification series would be included in the new Tax Auditor series This
belief, as noted, was premised on the Union's reading of the strip list and on the Employer's
failure to dispute the Union's tally of affected employees The Union's understanding of the
bargain was communicated to its members on March 18, 1999 when it outlined the details of
a tentative settlement in a publication titled "Table Talk", the material part of which stated
"About 1,000 Financial Officers and the four Tax Auditors in the
Ministry of Finance will receive $3375 million through the creation
of a new Tax Auditor series"
(Exhibit #3, Tab #9)
Mr Coates, unlike Mr Nield, did not participate in the negotiation of the Letter of
Understanding He, nevertheless, maintained that the Investigators should also have been
moved from the Financial Officer 5 to the Tax Auditor 5 classification pursuant to the terms of
the aforementioned Letter It was the substance of his evidence that Investigators are tax
auditors as they perform audits as part of their job Mr Coates further asserted that the
Employer, and indeed taxpayers generally, consider the Investigators to be tax auditors
Mr Coates stressed that following the movement of Tax Auditors into the Financial
18
Officer series in the mid-1980's and the decision in Alton et ai, the Investigators were at the
same level as the Senior Tax Auditors in the Corporate Tax Branch and the Retail Sales Tax
Branch All of these positions were then classified and paid at the Financial Officer 5 level (I
note at this juncture that Tax Auditor positions were designated as atypical within the
Financial Officer series) Mr Coates described what occurred here as a demotion On his
analysis, the position of Investigator is of equal value to the jobs held by the Senior Auditors
In Mr Coates' words, "they are tax auditors, we are tax auditors" Accordingly, he advanced
the position that the Investigators should have been similarly moved into the new Tax Auditor
series following the Letter of Understanding thus entitling them to the substantially increased
salary provided for therein Put another way, in Mr Coates' judgment, there was no sound
reason for discontinuing approximately fourteen (14) years of equal treatment of the two (2)
groups of employees
Mr Coates noted that the purpose of the Investigator position, as described in the
Position Specification and Class Allocation form, specifically contemplates the conduct of "in-
depth audits" In this regard, he compared the type of audits performed by Tax Auditors to
those completed by the Investigators From his perspective, employees now in the new Tax
Auditor series are "generalists" who compare taxpayer remittances to a given standard
provided for in the tax statutes In contrast, Mr Coates described the Investigators as
"specialists" who must perform "forensic audits" More specifically, employees in the latter
position are required to determine, through the exercise of audit and investigatory techniques,
whether reasonable and probable grounds exist to believe that offences have been
19
committed under tax legislation so as to support the commencement of a prosecution Mr
Coates described this process as a "tax audit" Prosecution Reports prepared by Mr
Coates were submitted in Reply as Exhibits #17 and #18
The regulatory or audit powers of both Tax Auditors and Investigators are set out in
sections 31 (1) and (2) of the Retail Sales Tax Act. Under section 31 (1), persons duly
authorized by the Minister may enter business premises and proceed to audit or examine
books, records or other relevant documents or to examine property for purposes related to the
administration or enforcement of the Act. Section 31 (2) authorizes the Minister to demand the
production of information IT business records from any person or business for the same
purposes Sample Requirement for Information forms were filed in this proceeding as
Exhibits #19 and #20 Mr Coates testified that the above powers can only be used by an
Investigator to the point at which he/she determines reasonable and probable grounds exist to
believe an offence has been committed Once that point is reached, the Investigator must
caution the taxpayer as to the effect of any statements made and must also resort to a search
warrant to obtain relevant information or documents If an Investigator fails to comply with
such requirements, any evidence obtained will likely be deemed inadmissible by the Court
adjudicating the charge In this regard, reference was made by Mr Coates to the cases of
R v Jarvis, a 1997 decision of the Alberta Provincial Court, and Re Colarusso (not provided
or cited), which impose the requirements mentioned above I consider that two (2)
conclusions can be drawn from Mr Coates' evidence on this point. Firstly, Investigators,
similar to Tax Auditors, have the audit or regulatory powers provided for under the Retail
20
Sales Tax Act. Secondly, the Investigator is only entitled to use such powers to the point of
reasonable and probable cause This reqLires the Investigator to make an informed
determination as to when that threshold is reached The Tax Auditor does not have to
address this issue nor confront the legal consequences of failing to make such a
determination
Mr Coates advised that certain positions which do not require the performance of
audits were moved to the new Tax Auditor series following the Letter of Understanding He
mentioned the position of Standards Officer, Audit Control Prior to the negotiations, this
position was classified as Financial Officer 4 (Atypical) The Position Specification and
Class Allocation form describes the purpose of this position as follows
"Under the direction of the Senior Standards Officer, assists in the
setting of audit standards, measures adherence to the standards
and provides guidance in the meeting of the standards by.
Conducting quality control reviews of all functions within the Audit
Section of the Retail Sales Tax Branch, Establishing audit
standards and methodologies, "
(Exhibit #6)
This position was assigned to the Tax Auditor 4 level in the new class series The purpose of
the position is described as follows in the Position Description Report:
"To develop, recommend, maintain, and update retail sales tax
audit standards, to provide guidance to audit staff through training
and support and to prepare, maintain and update
technical/administrative handbooks to reflect audit standards,
policies and procedures To participate as a member of the
Audit Handbook committee, the Technology Committee, the
Training Committee, the Audit Consistency Committee, and the
Refund Committee which seUestablish standards"
21
(Exhibit #3, Tab #5)
It was the gist of Mr Coates' evidence that if the above position was considered as one of
"the positions of Tax Auditors" for purposes of the Letter of Understanding, so should the
position of Investigator, especially given the fact that incumbents in the latter job are required
to perform audits
Mr Coates testified that he was issued an Identification Card when he commenced
employment with the Special Investigations Branch He stated that his card was identical to
one (1) issued to Mr Phil Roberts, one (1) of the other grievors, which was filed as Exhibit #4
in this proceeding That card states on its face
"The above employee is an officer of the Ministry of Finance
authorized to perform audits and inspections pertaining to the
Statutes referred to in Section 4 of the Ministry of Revenue
Act. "
This type of card is used by the Investigator to identify themselves to the taxpayer Mr Coates
highlighted the words "perform audits" on the card He advised that his card, which expired
on December 31, 1999, was handed in to support staff Mr Coates indicated that the
replacement card, which he subsequently received, identified him as an Investigator in the
Special Investigations Branch This change to the descriptive text on the card occurred after
the negotiation of the Letter of Understanding
Mr Coates referenced an Employer generated document entitled "Tax Division
Position, Accreditation Requirements for Tax Auditors" (Exhibit #3, Tab #2) He believed that
22
this document, which he received in August or September, 1998, was prepared by Human
Resources as part of the bargaining unit overhaul process Mr Coates thought it material that
Financial Officers 5 in the Special Investigations Branch were included on this list relating to
Tax Auditors When asked about the significance of the document, re replied "They have
included us in the accreditation requirements for tax auditors indicating to me they consider
us to be tax auditors" Mr Coates was not prepared to concede that the inclusion of
Investigators in the chart may have been an oversight.
Mr Coates also testified that he and other Investigators were invited to a Tax Auditors
Conference in 1984 Documentation relating to this event was filed as Exhibit #3, Tab #7
Lastly, in his evidence, Mr Coates asserted that the Employer had experienced
difficulty prior to January, 1999 in attracting qualified applicants for Investigator positions He
stated that such a development would not have occurred prior to 1995, as the Special
Investigations Branch was then one (1) of the higher paying units in the field In cross-
examination, Mr Coates was confronted with data from competitions for Investigator
positions over the period from 1997 to 2000, inclusive The data seemed to suggest that the
Employer has been relatively successful in filling such positions M r Coates responded to the
data by stating, "We have lowered our standards" He suggested that the skill of new hires is
lower in the areas of fraud awareness and auditing and stated that they require more training
than was previously the case
Mr Farragher noted that there was a significant increase in the "hidden economy" in
23
the late 1990's This was also a period in which the Provincial Government experienced large
deficits Mr Farragher advised that at the time there were an insufficient number of Tax
Auditors available to address the loss of revenue from the hidden economy Apparently, this
situation was the subject of some comment by the Provincial Auditor As a consequence of
all of the above, a submission was made to Management Board of Cabinet for funds to
increase the complement of Tax Auditors so as to promote greater tax compliance This
expenditure was ultimately approved and was announced in the Budget in the Spring of 1998
The initiative was titled the Tax Integrity Program (TIP2)
Mr Farragher advised that recruitment under TIP2 commenced in the summer of 1998
He stated that the Ministry of Finance was looking to hire approximately four hundred (400)
employees, about three hundred and seventy (370) of whom were to be auditors The
balance of the new hires were to be Collectors, Special Investigators and some "compliance
types" In cross-examination, Mr Farragher clarified that the compliance personnel he was
referring to were clerical staff who monitor tax remittances and whose work may lead to
random or planned audits by the Tax Auditors
Mr Farragher advised that the initial recruitment initiative was only fifty percent (50%)
successful and that the Employer experienced significant difficulty in attracting auditors,
particularly at the senior level He attributed this problem to the fact that Revenue Canada, a
major competitor in the labour market, was about to hire between six hundred (600) and one
thousand (1,000) auditors at a rate of pay greater than could then be offered by the Employer
In view of this situation, Mr Farragher wrote to Ms Pat Werner, Director of the Compensation
24
Branch of Management Board Secretariat, by letter of August 21, 1998 (Exhibit #8, Tab #7)
Mr Farragher documented the reasons why the Ministry of Finance was having difficulty
competing with Revenue Canada for auditors The last paragraph of his letter reads, in part:
"My purpose in writing is to request a meeting with you to begin
discussions on how we can find creative ways to respond to and
counteract the Revenue Canada initiatives so that the Ontario
Government's tax revenue generation strategy is not
derailed "
Mr Farragher asserted that this letter was written in respect of Tax Auditor compensation He
stressed that the letter had nothing to do with Investigators
Mr Farragher wrote a second time to Ms Werner by letter of October 30, 1998
(Exhibit #8, Tab #8) He spoke in the letter of the campaign to hire three hundred and sixty-
four (364) auditors in addition to the "normal annual attrition recruitment of approximately 80
to 100 auditors" He also reiterated his concern about the Employer's ability to compete with
Revenue Canada for auditors Mr Farragher attached a chart titled "Comparison of Tax
Auditor Salary Scales" to his letter The chart compared the salary paid to auditors in the
Financial Officer, Financial Administration and Tax Auditor 3 classifications to comparable
positions at Revenue Canada The chart showed a variance of eleven and two-tenths percent
(11 2%) at the Financial Officer 5 level in favour of employees working for Revenue Canada. I
note, in passing, that the variances set out in the chart are essentially the same percentage
increases provided for by the Letter of Understanding As was the case with the earlier letter,
Mr Farragher testified that his second effort applied to Tax Auditors and not to Investigators
25
Mr Farragher subsequently met with Ms Werner and others on this issue He
observed that by then the matter was complicated by the bargaining unit overhaul There was
talk at the meeting of implementing a new Tax Auditor series and of a "special allowance
payment option" Mr Farragher stated that the problem was ultimately solved at the
bargaining table when the plan for a bargaining unit overhaul was dropped As a
consequence, the Employer elected to table its proposal around Tax Auditors at the
Administrative Category negotiations
Mr Farragher testified that the Employer by this time had already costed the proposal
on the understanding it would affect approximately one thousand (1,000) Tax Auditors,
including those to be hired The costing, which utilized the Revenue Canada rates, had been
part of the original package submitted to Management Board of Cabinet in the Spring of
1998 Mr Farragher agreed that if all of the Financial Officer positions shown on the strip list
were added together, the total would be just under one thousand (1,000) He had no personal
knowledge of the Union having expressed its view that nine hundred and ninety-eight (998)
Financial Officers would be affected by the proposal
As mentioned earlier, Mr Farragher was not at the bargaining table when the
Employer presented its proposal on the classification adjustments here in issue Given his
prior involvement with the recruitment initiative, he was, however, well aware that such
proposal was to be offered Mr Farragher testified that he did not have any discussions with
the Administrative Category Bargaining Team, including Ms Crawford, in advance of the
26
proposal to advise them what Tax Auditor positions were intended to be captured He
acknowledged that Team members did report back to the Central Table Mr Farragher did
not recall Ms Crawford coming to him during the course of negotiations to advise that the
Union had asked about the number of Financial Officers who would be impacted by the
proposal
Mr Farragher stated that the proposal, which ultimately became the Letter of
Understanding, was intended to address the situation affecting the Tax Auditors in the Ministry
of Finance He asserted in chief that the proposal did not apply to the Investigators and that
he never understood Investigators to be Tax Auditors In cross-examination, Mr Farragher
agreed hat Investigators perform audits It was his judgment, however, that they do not
perform tax audits Mr Farragher advised that the phrase "positions of Tax Auditors" was
intended to encompass "groups of employees involved in tax assessing and auditing Dr
purposes of tax correctness or tax liability" He was prepared to acknowledge that
Investigators audit for purposes of determining tax liability He added that such responsibility
"isn't their sole function in the Ministry"
During his cross-examination, Mr Farragher's attention was directed to a document
titled "Positions Included In Tax Auditor Class Series" (Exhibit #10) The positions listed are
as follows Jr Returns Auditor, Desk Auditor, Returns Auditor, Field Auditor-Employer
Accounts, I and C Field Auditor, Field Auditor, Sr Auditor Desk, Field Auditor Trainee, Field
Auditor Complex Employer Accounts, Sr Field Auditor, Tax Auditor Field, Standards Officer-
27
Audit Analysis and Control, and Sr Auditor Field With the exception of Sr Auditor Desk, all
of these positions were classified as atypical in the Financial Officer series prior to being
moved to the new Tax Auditor Class Series Mr Farragher agreed that only one (1) of the
positions, this being Tax Auditor Field, is specifically titled Tax Auditor He then stated that "a
title is a title" and "what is critical is the function of the position, why it is performed and why
we created them" Mr Farragher added that, "we knew what we meant by Tax Auditor when
we made our submission" It was the thrust of his evidence that the Employer did not intend to
capture Investigators in its proposal
Lastly, Mr Farragher stated that he has recently been made aware that there is a
shortage of Investigators He advised that he was not aware of such a shortage at the time
the new series was established
As previously mentioned, Mr Coates referenced a document titled "Tax Division
Position, Accreditation Requirements for Tax Auditors" (Exhibit #3, Tab #2) in support of his
assertion that the Employer considers the Investigators as Tax Auditors Ms Ecker, in her
evidence, addressed the development and purpose of the document. Her evidence on this
issue may be summarized as follows
(i) In 1995, the Tax Revenue Division undertook a review of he
accounting accreditation requirements within the Division One
(1) of the findings emanating from the review was that the
accounting accreditation for positions in the Ministry of Finance
might operate as a systemic barrier to employment. The
original version of the chart was prepared so as to introduce
the concept of academic equivalents to the accounting
accreditation requirements applicable in the Division
28
This initial chart was filed in this proceeding as Exhibit #8, Tab
#1 While Ms Ecker was not involved in the development of
this chart, she seemed to be well-informed as to its content;
The original chart which was titled "Tax Division Position,
Proposed Accreditation Requirements for Tax Auditors"
included the Financial Officer 5, Investigator position In her
examination in-chief, Ms Ecker stated that to her knowledge,
the Investigators are not Tax Auditors In cross-examination,
she agreed that they perform audits on books and records but
noted that they do not raise assessments after the audit. Ms
Ecker further stressed that the I nvestigators have other
responsibilities Ms Ecker referenced a number of other
positions in the Division classified at the AM-19, AM-20 and
SMG-1 levels which were similarly listed on the chart even
though they were not Tax Auditor positions Ms Ecker testified
that the focus of the discussion at the time this chart was
prepared was on what combination of courses could be
considered as the equivalent of the accounting designation,
(i i) Ms Ecker referred to a list of issues given to her by the Senior
Audit Manager who chaired the group looking at academic
equivalents in preparation for a meeting to be held in
November, 1997 with the Assistant Deputy Minister of the Tax
Revenue Division The list, filed as Exhibit #8, Tab #2, reads in
part:
"Should the accreditation requirements
apply to AUDIT positions only or to AUDIT
and NON-AUDIT positions e g positions
in TAB and SIB, and NON-Audit SMG's?"
(i i i) Ms Ecker's handwritten notes taken at the meeting of
November 24, 1997 (Exhibit #8, Tab #3) suggests that those in
attendance considered the Investigators in the Special
Investigations Branch to be in non-audit positions It further
appeared to be the consensus that there should be an
academic equivalent to the accreditation requirement for
Investigators An E-Mail was subsequently forwarded to the
Human Resources Branch by the Assistant Deputy Minister of
the Tax Revenue Division asking that the issue be proceeded
with on that basis (Exhibit #8, Tab #4),
(iv) The chart referenced by Mr Coates was produced by the
29
Human Resources Branch in 1998 Ms Ecker sat in on the
meetings at which the content of the chart was discussed and
took direction on the production of same,
(v) The current version of the chart dated August 17, 1999 was
filed as Exhibit #8, Tab #5 Ms Ecker noted that the Special
Investigation Group is no longer referenced on the chart. Ms
Ecker testified that she was asked to delete them from the list
because they are not Tax Auditors She stated, in effect, that
she agreed with that assessment. Ms Ecker advised that the
I nvestigators were on the 1998 chart because it was
determined that Financial Officer 5 positions in the Special
Investigations Branch ought to require accounting credentials
or an academic equivalent. She agreed that this current chart
was prepared after the implementation of the new Tax Auditor
series
Ms Ecker, in her evidence, also referred to the Preamble to the Financial Officer 1-3
Class Standards (Exhibit #8, Tab #6) She did so to demonstrate that there are numerous
positions in the classification, which are not Tax Auditor positions The positions of Financial
Analyst, Budget Officer, Rate Analyst, Senior Rate Analyst, Land Transfer Tax Analyst,
Centralized Financial Analyst, and Senior Financial Analyst were cited as relevant examples
Lastly, Ms Ecker expressed the opinion that the Letter of Understanding was to apply
to Tax Auditors and not to Investigators She repeated her understanding that Investigators
are not Tax Auditors
As stated earlier, Ms Crawford was the Employer's lead spokesperson at the
Administrative Bargaining Unit table It was her evidence that when the proposal was
presented, the Union was informed that approximately one thoLSand (1,000) Tax Auditors
30
would benefit from the classification adjustment. Ms Crawford testified that the Union
questioned that number as its representatives were under the impression there were only four
(4) Tax Auditors Ms Crawford stated that the negotiations were then adjourned for a short
time to enable the Employer team to seek clarification so as to enable it to better provide an
explanation for the large discrepancy in the numbers Ms Crawford subsequently "connected
up" with Ms Gail Fisher, Manager of Union-Management Relations, Management Board
Secretariat, and Ms Angela Sullivan, who worked in the Classification Unit, for this purpose
Ms Crawford testified that she and Ms Sullivan discussed how the new grids would
apply Part of their discussion focused on the fact that not everyone in the Financial Officer
category would move into the new Tax Auditor series, as there were employees in the former
category who were not Tax Auditors Ms Crawford determined that those employees would
not move to the new Tax Auditor range Ms Crawford stated that there were no specific
discussions about precisely which positions would move She did, however, obtain
confirmation that there were approximately one thousand (1,000) Tax Auditors who would be
affected She learned that this included a large number of Tax Auditors who were classified
as Financial Officers and four (4) employees who were actually classified as Tax Auditors
Ms Crawford subsequently conveyed the substance of the above discussion to Mr
Nield and Ms Moya Beall, another member of the Union's bargaining team M s Crawford
testified she told them that there were four (4) Tax Auditors in the wage schedule She further
advised Mr Nield and Ms Beall that there were also a number of Tax Auditors classified as
31
Financial Officers who would be affected by the proposal It was Ms Crawford's evidence
that she was asked by the Union's representatives if the Employer was going to delete the
Financial Officer classification from the collective agreement. Ms Crawford stated that she
informed them that was not the Employer's intent as there were other staff in the Financial
Officer series who were not Tax Auditors At the time she made this statement, Ms Crawford
did not have any independent knowledge that the Ministry of Finance employed Investigators
Ms Crawford testified that the strip list was never referenced during the course of the
negotiations She did not recall Mr Nield looking at such a list when at the table She further
asserted that neither Mr Nield nor Ms Beall referred to the strip list when addressing the
impact of the proposal Ms Crawford could also not recall Mr Nield expressing the Union's
understanding that nine hundred and ninety-eight (998) Financial Officers would be affected
by the proposal
In her evidence in-chief, Ms Crawford stated that "our proposal afforded a class
adjustment only to those who were Tax Auditors" In cross-examination, she agreed that it
was positions of Tax Auditors which would benefit from the adjustment and not merely
employees classified as Tax Auditors Ms Crawford commented as follows on this point:
"I knew there would be a whole number of people who were
Financial Officers who were not Tax Auditors and I knew there were
some Financial Officers who were Tax Auditors and that those who
were Tax Auditors were receiving the adjustment"
In response to a question from Union counsel, Ms Crawford indicated she assumed that the
32
employees to be moved performed tax audits She noted that the Investigators who were to
receive an adjustment are specifically mentioned on page 190 of the collective agreement
under the heading "ADM Inspectors/Investigators"
Ms Crawford's evidence conflicted with that of Mr Farragher on one (1) point. Ms
Crawford testified that she did have a conversation with Mr Farragher during the course of
the negotiations She stated that this conversation focused on the Employer's retention
problem arising from the Federal Government providing a better compensation package to
T ax Auditors
Ms Mason advised that there were two (2) phases to the Tax Integrity Program, these
being Phase One in 1996 and Phase Two in 1998 Both phases were part of a
comprehensive program to address the underground economy and promote tax compliance
Ms Mason worked on Phase Two of the Program which was introduced in the Spring 1998
Budget. At the time, Ms Mason was the Acting Director In this capacity, she was
responsible for coordinating the hiring under the Program It was her evidence that a total of
five hundred and sixty-two (562) employees were to be hired She broke down this total as
follows four hundred and forty-four (444) Auditors, fifty (50) Collection Staff, thirty (30)
Compliance Staff, and thirty-eight (38) positions in management and support functions Ms
Mason stated that the Program contemplated a seventy percent (70%) increase in the number
of Tax Auditors
33
Ms Mason asserted that the hiring initiative did not include any new Investigator
positions In this regard, she was confronted with Mr Farragher's statement that Investigators
were to be part of the hiring under the Tax Integrity Program Ms Mason, in substance, did
not agree She was then shown a document titled "Tax Integrity Program (TIP2) Update"
dated November 18, 1998 (Exhibit #15) On its face, the document indicated that thirty-nine
(39) "Investigations and Compliance" staff were to be hired Ms Mason explained that the
reference to Investigations was a typographical error and that the number of thirty-nine (39)
was to apply to "Identification and Compliance" staff She asserted that this mistake was
corrected in a later report. Ms Mason reiterated that the sub -group of thirty-nine (39) hires
did not include any Investigator positions I note that Mr Farragher stated in cross-
examination that there are two (2) groups of employees in the Ministry of Finance who are
called Identification and Compliance Field Officers One group is classified at the Tax Auditor
2 level and the other is in the OAG series
Ms Mason stated that the first phase of hiring under TIP2 commenced in July, 1998 The
Employer then posted competitions for three hundred (300) Tax Auditor positions Ms Mason
indicated that most of the positions were for Field Tax Auditors She advised that such auditors
attend at the taxpayer's place of business, conduct an audit of their books and records, and then
raise the assessment, if deemed appropriate Ms Mason testified that this initial round of
recruitment led to the hire of one hundred and sixty-one (161) auditors She noted that this
raised a "high level of concern" as the Employer could not meet the TI P2 commitment to raise
an additional seven hundred million dollars ($700,000,00000) with only that number of new
34
hires Ms Mason and others involved in the Program were worried that the competition with
Revenue Canada in the labour market would make it difficult for this Employer to recruit, and
indeed retain, staff
The Employer's failure to meet its hiring target motivated Mr Farragher to write the two
(2) letters to Ms Werner referenced earlier in this award It also led to a meeting in
December, 1998, after which a decision was taken to prepare a business case The purpose
of the busine ss case was as follows to identify problems in recruitment; to explore options, to
calculate the cost of making Tax Auditor salaries comparable to those paid by Revenue
Canada, and to isolate the implications if the Employer was unable to hire all of the necessary
T ax Auditors It was asserted by Ms Mason that the Investigators were never mentioned or
considered during the development of the business case Rather, the focus at all times was
on Tax Auditors
Ms Mason testified that she was asked by Management Board to provide a list of all
Tax Auditor positions that would be impacted by any change in salary and to break the total
number down by classification After receiving information from the Finance and
Administration Unit, Ms Mason prepared a chart titled "Tax Revenue Division, Approved
Auditing Staff Profile as at March 31, 1999" (Exhibit #8, Tab #9) The chart illustrates the
Auditor positions across the various Branches and the two (2) Regional Offices by number
and classification The total number of all such positions is shown as one thousand and
seventeen (1,017) Ms Mason asserted that this total figure included the new positions the
35
Employer hoped to fill through the TIP2 I take from her evidence that the chart was prepared
in either December, 1998 or January, 1999 as she believed the data shown thereon was
given to Management Board at some point during the latter month as part of the business
case The reference to March 31, 1999 on the document was not to show the date on which it
was prepared but, rather, to show desired complement on a fiscal year basis Ms Mason
stated that no Investigator positions were shown on the chart, as she did not consider
Investigators to be in Tax Auditor positions Ms Mason did not know if the information on the
chart, including the total number of Tax Auditor positions, was used in the course of the
negotiations
Mr Stangarone stated that the Identification Card referenced previously was changed
because it did not properly identify the Investigators As mentioned, Exhibit #4 states that Mr
Roberts, an Investigator, was "authorized to perform audits and inspections" In summary, Mr
Stangarone asserted it was crucial, following the Court decisions in Colarusso and Jarvis, for
Investigators b properly identify themselves to suspects, taxpayers and vendors Failure to
do so had the potential to render any evidence obtained inadmissible M r Stangarone
advised that the process of changing the cards started in the two (2) year period prior to
December 31, 1999 He indicated that it took a long time to finalize the process as the
change involved a lot of discussions Mr Stangarone testified that the change had nothing to
do with the reclassification of employees under the collective agreement
36
Mr Stangarone briefly described the flow of work as between Tax Auditor and
Investigator My understanding of his evidence is that the Tax Auditors in the various Product
Branches make referrals to the Special Investigations Branch in situations where, following an
audit, they suspect the taxpayer may have contravened tax legislation The Investigators then
proceed to commence an investigation and, if merited, make recommendations for the
commencement of prosecution Additionally, they assist with he prosecution through the
completion of a Prosecution Report and as witnesses Mr Stangarone, in cross-examination,
agreed that Investigators perform a complex audit in every file they take He further
acknowledged that such audit is done to a higher standard than ones completed by Field
Auditors Indeed, Mr Stangarone expressed the opinion that of the two (2) positions, the one
of Investigator is more complex as such employee is involved in the prosecution of an
individual audited initially by a Tax Auditor Mr Stangarone claimed, however, that he has
never considered I nvestigators to be Tax Auditors
During the course of his evidence, Mr Stangarone suggested that Investigators could
no longer use the regulatory powers under section 31 of the Retail Sales Tax Act when
approaching a taxpayer during an investigation Secondly, he expressed the opinion that it
would be unusual for a Tax Auditor's file to be placed before the Court as evidence Mr
Coates disputed both of these points in reply It was the substance of his evidence that an
Investigator remains entitled to use the regulatory powers up to the point of reasonable and
probable cause and that audit files are used in court to support the prosecution, as needed
37
It was the position of the Union that extrinsic evidence should be received to assist with
the interpretation of the Letter of Understanding This position was premised on the
submission that the phrase "positions of Tax Auditors", contained in the first paragraph of that
part of the Letter headed "Tax Auditors", reflects a latent ambiguity Counsel for the Union
referenced Exhibits #9, #10 and #11 which all list positions in the Tax Auditor series He
emphasized that none of the positions are specifically described as "Tax Auditor" Counsel
noted that the closest description is the position of Tax Auditor Field listed on Exhibit #10 He
submitted that as such position is not the only position included in the Letter of Understanding,
there must have been an intention to ascribe a broader meaning to the words "Tax Auditor"
In substance, it was the Union's argument that resort should be had to extrinsic evidence to
clarify the ambiguity and give meaning to the bargain reached by the parties
Counsel for the Union submitted thatthe evidence presented supports a conclusion
that Investigators are in positions of Tax Auditors within the Ministry of Finance He relied on
the following evidence, inter alia, in support of this position
(i) Mr Farragher's statement that the purpose of the Letter of
Understanding was to capture people holding positions which
assess and audit in order to determine tax liability and his
acknowledgement that Investigators engage in this function
Counsel noted that Mr Farragher, in contrast to Ms Mason,
stated that Investigators were included in TIP2,
(ii) The Position Specification and Class Allocation form for the
position of Investigator includes under "Purpose of Position"
the conduct of "in-depth audits" Specific mention was made
of the fact that lI>th M r Coates and M r Stangarone stated
Investigators perform audits Mr Stangarone testified that such
audits are done to "a higher standard" than those performed by
T ax Auditors Counsel asserted that there was no evidence to
38
establish a distinction between auditing and tax auditing He
further noted that, in any event, positions such as Compliance
Officers and Standards Officers were included in the new Tax
Auditor series even though they do not perform audits,
(iii) The evidence of Mr Coates of the Investigator's ability to use
regulatory powers up to the point of reasonable and probable
cause Counsel argued that this right confirms that
Investigators are in a Tax Auditor position in the sense there is
an "audit side" to their work. He suggested that the conflict of
views between M r Coates and M r Stangarone on the subject
simply reflects a debate as to the extent such powers can be
used,
(iv) The evidence of M r Coates relating to the Identification
Card, the Accreditation document, and the invitation to the
1984 Tax Auditor Conference From the perspective of
counsel, this evidence suggests that the Employer itself
considers Investigators to be Tax Auditors In this regard, I
was urged to be cautious with respect to evidence of events and
discussions following March, 1999 tendered in relation to the
identification and accreditation issues In counsel's
submission, such evidence is "self- serving"
Counsel for the Union also referred to the "Inspector/Investigators" portion of the Letter
of Understanding as found at page 190 of the collective agreement. He noted that the
Investigators in the Special Investigations Branch are not included therein and that all other
Investigators received the benefit of a salary adjustment. Counsel argued that this omission
confirms the parties' intent to include this group of Investigators in the new ranges for Tax
Auditors set out at page 189 of the collective agreement. I was asked to conclude that if the
parties wished to exclude these Investigators from the benefit of same, they would have used
clear language to that effect.
39
Ultimately, it was the position of the Union that the evidence supports a declaration that
the Investigators are in "positions of Tax Auditors" and are, therefore, entitled to inclusion
within the Letter of Understanding I was further asked to declare that the Employer breached
the collective agreement by failing to adhere to the bargain contained within the Letter By
way of monetary remedy, it was submitted by counsel for the Union that damages are easily
ascertainable, as they would be measured by the new wage rates paid to other positions of
Tax Auditors in the Ministry of Finance, which benefited from the Letter of Understanding
Counsel submitted that the grievors would be entitled to such damages "until the Employer
takes action in respect of the true intent of the Letter of Understanding"
Counsel emphasized that he was not asking for an order that the grievors be
reclassified In his submission, the creation of a new classification or the alteration of an
existing one is not a precondition to an award of the damages claimed He argued that the
matter of determining the intention of the parties as to who is in a Tax Auditor position is a
legitimate issue for this Board's decision Counsel asserted that the fact interpretation of the
Letter of Understanding may touch on classification matters does not transform this case into
a classical classification case of the type precluded by sections 51 and 52 of the Crown
Emplovees Collective Barqaininq Act.
The Union relied on the following awards Re Inn of the Woods and United Food and
Commercial Workers, Local 175 (1989), 7 L.A.C (4th) 31 (Aggarwal), OPSEU (Union
Grievance) and the Crown in Riqht of Ontario (Ministry of Revenue), GSB No 802/91,225/92
40
(Watters), OPSEU (Theoret) and the Crown in Riqht of Ontario (Ministry of Finance), GSB No
1674/93 (Roberts), OPSEU (Barker et al ) and the Crown in Riqht of Ontario (Ministry of The
Attorney General), GSB No 2476/92 (Kaplan)
It was the position of the Employer that I lack jurisdiction to award the monetary
remedy claimed by the Union Counsel for the Employer noted that the damages claimed
are the equivalent of the extra compensation the grievors would have received had they
been moved to the new Tax Auditor series He submitted that if the grievors were awarded
damages on this basis, it would be tantamount to putting them into the new series which
would thereby change or alter their classification Counsel argued that sections 51 and 52
of the Crown Employees Collective Barqaininq Act clearly deprive this Board of the
jurisdiction to make such an award He asserted that this result would still obtain even if I
were to find that the parties intended to capture the Investigators in the Letter Of
Understanding In the words of counsel, the Union was attempting to create "a tortured
remedy" or "a backdoor route" to avoid the clear statutory prohibition to my jurisdiction
It was the further position of the Employer that the wording of the Letter Of
Understanding is clear and unambiguous Counsel submitted that a plain reading of the
document discloses that it was intended to apply to Tax Auditors and not to Investigators
He emphasized that the Letter does not speak to, or mention, Investigators In his
submission, it was intended to address Tax Auditors who were formerly classified atypically
in the Financial Officer series Counsel argued that given the clear language found in the
41
Letter Of Understanding, it is irrelevant that Investigators have historically been
compensated at a level similar to Tax Auditors or that their job in some respects may be
more complicated For all of these reasons, I was asked to not resort to the extrinsic
evidence in aid of interpretation
Assuming the existence of an ambiguity and the consequent consideration of the
extrinsic evidence, Counsel for the Employer next addressed what he viewed to be the two (2)
primary arguments of the Union which he described as
1 The parties specifically negotiated to convert approximately
one thousand (1,000) Financial Officers and four (4) Tax
Auditors to the new Tax Auditor series and that these numbers,
in and of itself, dictate that the grievors were contemplated to
fall within the Letter Of Understanding, and
2. The Investigators are Tax Auditors and, as such, the parties negotiated to place them
as Tax Auditors into the new series
Counsel stated that the evidence relating to the above arguments should not be considered or
relied on unless I found the language of the Letter Of Understanding to be ambiguous in a
patent or latent sense
With respect to the first of the Union's arguments, counsel for the Employer made the
following submissions
(i) The evidence adduced through Mr Farragher rrakes it clear
that the Ministry of Finance was attempting to increase its
complement of Tax Auditors The recruitment and retention
problems documented in his letters to Ms Werner address Tax
Auditors and not Investigators Counsel noted that, ultimately,
the Employer decided to deal with the recruitment problem
42
through collective bargaining given the relative lack of success
in hiring under TIP2 He questioned why the Employer would
include the Investigators in this resolution of the recruiting
impasse, if they were not part of the identified problem at first
instance It was the gist of counsel's argument that, in the
circumstances, it made greater sense to conclude that this
exercise in collective bargaining concerned Tax Auditors and
not I nvestigato rs In this regard, I was asked to accept the
evidence of Mr Farragher vis-a-vis the background and context
leading to the negotiation of the Letter Of Understanding,
(i i) Counsel referenced the chart prepared by Ms Mason which
showed a total desired complement of one thousand and
seventeen (1,017) Tax Auditors He submitted that this was
the number of Tax Auditors who would be affected by the Letter
of Understanding He referenced Ms Mason's evidence that
she did not include any Investigator positions in the count. I
was asked to conclude that the total figure of
one thousand and seventeen (1,017) formed the basis for M s
Crawford's statement at the bargaining table that
approximately one thousand (1,000) employees would be
impacted by the Employer's proposal, and,
(i i i) Counsel referenced Ms Crawford's evidence to the effect that
the proposal was to apply to one thousand (1,000) Tax
Auditors He suggested that the Union, on being told by Ms
Crawford that the Financial Officer series was not to be
deleted, should have known the proposal applied only to those
Financial Officers who were Tax Auditors Counsel noted that
if all the Financial Officers were to move to the new series, as
per the Union's understanding, the Financial Officer series
would essentially be vacated I n this respect, I was asked to
find that Ms Crawford's evidence made more "logical sense"
than that presented by Mr Nield Counsel noted that the
evidence of Ms Crawford and Mr Nield was consistent on one
(1) material point; that is, that there was no specific mention or
discussion at the table about including Investigators in the
Letter Of Understanding
Counsel presented the following submissions on the second of the
Union's arguments
(i) Reference was made to the evidence of Mr Farragher, Ms
43
Ecker, Ms Mason and Mr Stangarone Each of these
witnesses testified that they never considered I nvestigators to
be Tax Auditors Counsel for the Employer acknowledged that,
at times, the Investigators perform audits and tax audits He
asserted, however, that it is clear from the evidence they are
not Tax Auditors Counsel noted that the Alton decision
recognized that Investigators require two (2) core skills when
they engage in the full scale investigation of suspected fraud,
these being financial and accounting skills and investigation
skills He submitted that their "dual role" is reflected in the
Position Specification and Class Allocation form under
"Purpose of Position" It was his submission that Investigators
have significant responsibilities "far outside of the Tax Auditor
function",
(i i) Counsel suggested that the jurisprudence, such as Jarvis and
Colarusso, distinguish between the role of Tax Auditor and that
of Investigator He stated that the corresponding rights of the
taxpayer are dependent upon which role is being performed
Counsel submitted that these different roles or functions are
reflected in the respective position specifications,
(i i i) The evidence of Ms Ecker demonstrates that the
"Accreditation Requirements for Tax Auditors" document
(Exhibit #3, Tab 2) was not intended to establish that
Investigators occupy positions of Tax Auditors Rather, the
document was created as part of a process to assess whether
there should be an academic equivalent for an accreditation
requirement. Counsel noted that Ms Ecker, who played a role
in the creation of the document, does not consider Investigators
to be Tax Auditors,
(iv) The evidence of Mr Stangarone with respect to the
Identification card, the change made thereto, and the exercise
of regulatory powers illustrates that there is a material
distinction between audit and investigation functions,
(v) The evidence of Mr Coates in respect of the invitation to a
1984 Tax Auditors' Conference should be given little, if any,
weight given the long period of time between that event and the
negotiations central to this dispute, and
(vi) Counsel advised that a number of Inspector positions were not
addressed in the "Inspectors/Investigators" section of the Letter
44
Of Understanding at page 190 of the collective agreement. He
submitted that, given the fact it is not a comprehensive list, the
Union could not validly argue that the omission of the
Investigators from same meant that they must be included in
the Tax Auditor section of the Letter
In summary, it was submitted that the extrinsic evidence supports the position taken by
the Employer in this case Alternatively, counsel suggested that it is of no assistance in
respect of how the Letter Of Understanding should be interpreted and applied and, as a
consequence, the language as written should be construed on an objective basis It was the
submission of counsel that, in either case, the only proper conclusion is that Investigators are
not Tax Auditors In his view, "positions of Tax Auditors" was meant to capture employees in
positions in which the primary purpose is the completion of tax audits He asserted that such
a responsibility is not at the core of what these grievors do Rather, "their investigative and
prosecutorial functions make them what they are"
Counsel for the Employer relied on the decision in Crai(:l Grimes, previously cited, in
support of his submissions
In reply, counsel for the Union emphasized that several positions were moved into the
new class series even though they do not involve the performance of audits I n contrast, he
alluded to the fact that Investigators perform audits to a high standard It was his submission,
therefore, that they satisfy the core function test adva need by the Employer Finally, counsel
focused on the fact that counsel for the Employer did not list any Investigators missing from
45
the list on page 190 of the collective agreement.
The Board in Craig, Grimes set out the following test for the receipt of extrinsic
evidence in aid of interpretation
"Now we turn to consider whether the Board should rely on extrinsic
evidence relating to negotiating history leading up to this
settlement. Such evidence may only be used by the Board as an
aid to interpreting the language of the settlement, if the Board finds
the language used to be patently or latently ambiguous Patent
ambiguity is where the language used is on its face
ambiguous This would be the case where particular words or
phrases used have different possible meanings We have no
difficulty concluding that the disputed language in the settlement
document is not ambiguous on its face
Latent ambiguity is where the language, though clear on its face,
creates ambiguity in application and in practice However, one
must be very careful in determining whether a latent ambiguity
exists Often the language used by the parties may be capable of
different hterpretations and constructions The notion of latent
ambiguity, however, does not include generally "all cases of
doubtful meaning or application" (Leitch Gold Mines Ltd v Texas
Gulf Sulphar Co lnc, (1969) 1 0 R 469 at p 524) As arbitrator
Weatherill stated in Re lnt'l Nickel Co of Canada, (1974) 5 L.A.C
46
(2d) 331 at p 334, the notion of latent ambiguity "should not be,
and was not intended to be taken so far as to open the door to the
admission of extrinsic evidence whenever a disagreement as to
the construction of a document arises If that were allowed, the
strength of a document such as a collective agreement would be
greatly reduced, and the well-established rules respecting the
admission of extrinsic evidence would be meaningless" The mere
fact that the application of the plain meaning of the language used
leads to unfair or illogical results also should not automatically lead
to the admission of extrinsic evidence The process of collective
bargaining is such that not infrequently, under the severe pressure
to reach a settlement and end protracted negotiations, parties may
agree to language despite the irrationality or unfairness
Sometimes a party may be willing to live with such a result because
as a trade off it had gained concessions from the other party in an
area it considers to be more important. Therefore lack of rationality
or fairness does not necessarily lead to a conclusion that the
document is latently ambiguous In our view, for there to be a
finding of latent ambiguity in terms of ambiguity in application, the
party alleging ambiguity must not only establish that the language
leads the irrational or inconsistent results, but that such irrationality
and inconsistency was such that it is reasonable to conclude that
the parties could not possibly have intended such results"
(pages 7 -9)
Applying this test to the language in issue in this case, I find that the first sentence of the Tax
Auditor section of the Letter Of Understanding is latently ambiguous More specifically, it is
unclear from the phrase "positions of Tax Auditors in the Ministry of Finance" who the parties
47
wanted to capture within the new class series As noted earlier, there is only one (1) position
that is actually described as a Tax Auditor, this being Tax Auditor Field It is undisputed that
the parties intended to include more than just this one (1) position in the Letter Of
Understanding Put another way, through their bargain they wanted the Letter to have a
broader application I have been persuaded that, in the circumstances of this case, extrinsic
evidence can be received given the existence of an ambiguity in application In my judgment,
such evidence is admissible to assist with the interpretation of the Letter Of Understanding
and to give meaning to the bargain reached by the parties
In view of the agreement reached on the opening day of this case, I think that the
extrinsic evidence should be assessed on the following basis firstly, what does it disclose as
to the parties intent and state of mind when at the bargaining table and, secondly, does it
establish a context for the negotiations that might provide some assistance in determining the
intended effect of the Letter Of Understanding
Mr Nield and Ms Crawford were the mly witnesses presented by the parties who
were actually at the negotiating table It is apparent from their evidence that no specific
agreement was reached at the table vis-a-vis the Investigators The I nvestigators were not
discussed as a separate group as neither Mr Nield nor Ms Crawford had any knowledge
about such position at the time they were involved in the negotiation of the Letter Of
Understanding
48
Mr Nield and Ms Crawford left negotiations with different understandings as to which
positions would be included in the new Tax Auditor series Mr Nield believed that all
positions in the Financial Officer series would be moved to the new Tax Auditor series This
belief was premised on the Union's reading of the strip list and on the Employer's alleged
failure to dispute the Union's tally of nine hundred and ninety-eight (998) affected employees
Ms Crawford, initially advised the Union that approximately one thousand (1,000) Tax
Auditors would be impacted When this figure was questioned, Ms Crawford sought
clarification from Ms Sullivan She then informed the Union that the employees who would be
affected were Tax Auditors classified as Financial Officers and four (4) employees who were
already classified as Tax Auditors Ms Crawford also advised the Union representatives that
the Financial Officer classification would not be deleted, as there were other staff within that
series who were not Tax Auditors Ms Crawford asserted that her statement of the number of
affected employees was not based on the strip list. It was her evidence that the strip list was
not used by the Employer team and that the Union representatives never referenced such a
list during the course of the negotiations
Ms Crawford's evidence is consistent with that presented by Mr Farragher and Ms
Mason Mr Farragher testified that the Employer costed its proposal prior to bargaining on
the understanding it would affect approximately one thousand (1,000) Tax Auditors Ms
Mason, in advance of the negotiations, prepared the chart showing that one thousand and
seventeen (1,017) Tax Auditor positions would be impacted by the change in salary Both
witnesses stated that Investigators were not included in the total, as they were not considered
49
to be in Tax Auditor positions
In summary, Mr Nield claimed Investigators were to be included in the new class
series as it was his understanding from the strip list, and the Employer's failure to contest the
Union's estimate of affected employees, that all positions in the Financial Officer
classifications would be moved to the new Tax Auditor series Ms Crawford, in contrast,
asserted that only those Financial Officers who were Tax Auditors would be captured by the
Letter Of Understanding I conclude, from a review of all of the evidence, that the parties did
not have a common understanding as to the meaning of the phrase "positions of Tax Auditors
in the Ministry of Finance" when they agreed to the proposal on March 18, 1999 While the
parties had similar views as to the number of employees who would be affected, they differed
as to the composition of such group Given Ms Crawford's comments to the Union, I think it
should have been apparent that the Employer did not accept the Union's assessment of the
positions to be affected
The context evidence presented by the parties related to the following issues (i) the
background and purpose of the proposal, and (ii) whether the Investigators are Tax Auditors
and are perceived as such by the Employer
Evidence relating to the background and purpose of the proposal was presented by
Mr Farragher, Ms Mason and, to a lesser extent, by Ms Ecker Mr Farragher described the
reason for TIP2 and outlined what the Program entailed, particularly in terms of hiring It was
50
his evidence that almost all of the hires' were to be Tax Auditors More specifically, he stated
that three hundred and seventy (370) of the four hundred (400) new positions were to be Tax
Auditor positions It was the thrust of Mr Farragher's evidence that TIP2 recruitment was
primarily directed towards Tax Auditors and not Investigators Mr Farragher also described
the problems experienced during the recruitment process These problems were
documented in his letters of August 21 and October 30, 1998 to Ms Werner Mr Farragher
testified that the letters had nothing to do with Investigators but related, rather, to Tax Auditor
positions
Ultimately, because of the relative lack of success in the recruitment phase, the
Employer opted to look to the bargaining table for a resolution to the problem This change in
approach led to the development of the Employer's proposal Mr Farragher asserted that the
proposal presented on March 17, 1999 was intended to encompass Tax Auditors and not
Investigators In his words, it was designed to capture "groups of employees involved in tax
assessing and auditing for purposes of tax correctness or liability" While Mr Farragher
agreed that Investigators audit in order to determine tax liability, he was adamant that they
were not contemplated by the proposal Ms Ecker similarly expressed the opinion that the
Letter Of Understanding was to apply to Tax Auditors and not to Investigators
Ms Mason was the person responsible for coordinating the hiring under llP2 She
stated that out of the five hundred and sixty-two (562) employees to be hired, four hundred and
forty-four (444) were to be auditors Ms Mason advised that, for the most part, the initial
51
postings were for Field Tax Auditors Ms Mason also referenced the Employer's failure to
meet its hiring targets She maintained that throughout the period of her involvement, the
focus at all times was on Tax Auditors
The background evidence clearly discloses that the proposal was developed to
confront a recruitment and retention problem relating to Tax Auditors and not Investigators
Given the nature of the problem and the unsuccessful attempt to address it through
recruitment under TIP2, it makes more logical sense to conclude that the subsequent efforts at
collective bargaining, which resulted in the Letter Of Understanding, were directed towards
T ax Auditors and not Investigators
There are two (2) conflicts in the evidence which merit mention at this juncture Mr
Farragher testified that under TIP2, thirty (30) of the four hundred (400) hires were to be
comprised of Collectors, Special Investigators, and "Compliance Types" In contrast, Ms
Mason said that the hiring did not include any Investigators She asserted, in this regard, that
the reference to thirty-nine (39) "Investigations and Compliance" staff shown on Exhibit #15
was a typographical error which should have read "Identification and Compliance" It was the
substance of her evidence that this group of thirty-nine (39) employees did not include any
Investigators Given that Ms Mason was the person responsible for coordinating the hiring, I
accept that she would likely have a more precise understanding of the specific details
surrounding same I note from Mr Farragher's evidence that there are in fact two (2) groups
of employees in the Ministry of Finance with the position title of "Identification and Compliance
52
Field Officer" Ultimately, I accept that there was to be no hiring of Investigators under TIP2
Even if there was to be SJch hiring, it is apparent from Mr Farragher's evidence that the
number of Investigator positions were minimal in comparison to the number of new Tax
Auditor positions It is abundantly clear from all of the evidence that TIP2 focused on Tax
Auditors
Mr Farragher stated that he did not recall Ms Crawford coming to him during the
negotiations to advise that the Union had inquired about the number of Financial Officers
who would be impacted by the proposal Ms Crawford testified that she did have a
conversation with Mr Farragher during the course of the negotiations It was her recollection
that it centred on the Employer's retention problem resulting from Revenue Canada providing
a better compensation package to its Tax Auditors If these separate recollections amount to
a conflict, it is one that I do not consider as material to the resolution of this dispute
Mr Coates testified, in effect, that Investigators are in positions of Tax Auditors He
referenced the Position Specification and Class Allocation form, under Purpose of Position,
which states, inter alia, that Investigators engage in the conduct of "in-depth audits" He
further noted that Investigators can use the audit powers under section 31 of the Retail Sales
Tax Act up to the poirt of reasonable and probable grounds Generally speaking, the
Employer witnesses did not dispute the fact that Investigators perform audits Mr Farragher
stated that they perform audits, but not tax audits Ms Ecker agreed that they perform audits
on books and records but noted that they do not raise assessments after such audits Mr
53
Stangarone testified that Investigators perform complex audits, which are done to a higher
standard than the ones completed by Field Auditors Notwithstanding these
acknowledgements, each of the Employer witnesses claimed that they never considered
I nvestigators to be Tax Auditors On this point, Mr Farragher indicated that the performance
of audits is not the Investigator's "sole function in the Ministry" In a similar vein, Ms Ecker
stated that Investigators have "other responsibilities" I further note that Ms Mason did not
consider Investigators to be Tax Auditors It was for this reason that she did not include them
in her chart prepared as part of the business case
I am left with the distinct impression that all of the Employer witnesses saw a material
difference between the positions of I nvestigator and Tax Auditor and that this difference
focuses on the investigative role inherent in the former position This difference is reflected in
the respective job specifications and is also recognized in recent jurisprudence, such as
Jarvis and Colarusso These cases appear to indicate that the two (2) positions have
different responsibilities and obligations and that the rights of the taxpayer are determined to
a large extent by what position they are interacting with I consider it significant that the
importance of the investigative component of the Investigator's work formed the basis for the
result in Alton et al The decision, in that instance, references the tasks of interrogating
witnesses, preparing and executing search warrants and summonses, instructing the Crown
Prosecutor and testifying as Crown witnesses The award in Alton et al also notes that the
position of Investigator requires more than financial and accounting skills In the final analysis,
and after a consideration of all of the evidence relating to this aspect of the case, I conclude
54
that greater weight should be accorded to the evidence presented by the Employer to the
effect that Investigators are not in positions of Tax Auditors
Mr Coates referenced the Accreditation document, the Identification Card and the
invitation to the 1984 Tax Auditors Conference in support of an assertion that the Employer
considers Investigators to be Tax Auditors I reject this assertion on the following grounds
(i) Ms Ecker, in her evidence, addressed the development and
purpose of the document entitled "Tax Division Position,
Accreditation Requirements For Tax Auditors" It is my
assessment such evidence demonstrates that the 1998 chart
was not intended to show Investigators occupy Tax Auditor
positions Rather, it was created as part of a process which
ultimately determined that an academic equivalent to an
accreditation requirement should be established for the
I nvestigator position In this regard, I note the initial version of
the chart included a number of positions that are not Tax
Auditor positions, exhibits were filed showing that, as of
November, 1997, Special I nvestigations Branch positions were
considered to be "non-audit positions", and such consideration
is consistent with the removal of Investigators from the current
version of the chart;
(i i) Mr Coates led evidence that prior to December 31, 1999, his
Identification Card stated he was "authorized to perform audits
and inspections" and that thereafter it was amended so as to
identify him as an Investigator I have not been persuaded that
the wording on the card is determinative of the issue now
before me I am satisfied that the earlier wording was
developed in the pre Jarvis and Colarusso era. It was only after
these decisions that greater emphasis was placed on the need
for proper identification so as to preserve the admissibility of
any evidence obtained Mr Stangarone testified that the
process of change commenced in the two (2) year period prior
to December 31, 1999 I accept his evidence that the change
had nothing to do with the grievors' claim to the classification
adjustment here in issue,
(i i i) Lastly, I am satisfied that little turns on the fact Investigators
55
were invited to attend a Tax Auditor Conference in 1984 That
invitation was extended quite a few years ago No evidence
was presented as to similar invitations in recent years to
support the existence of a consistent practice
After reviewing the extrinsic evidence, I am unable to find that the Union has
established a right, on the part of Investigators in the Special Investigations Branch, to be
included within the terms of the Letter Of Understanding Indeed, I find that such evidence is
more supportive of the position taken by the Employer I think it more likely that the Letter Of
Understanding was intended to apply to positions formerly in the old Tax Auditor classification
which were shifted to the Financial Officer series, and designated atypical, in the mid to late
1980's This would explain why the Standards Officer position, classified as Financial Officer
4 Atypical, was moved to the new Tax Auditor series even though incumbents therein do not
perform audits The position appears to be a support position for the audit function as it sets
standards for audits, measures adherence to standards, and provides guidance in the
meeting of such standards I have also considered the arguments of both parties as to the
effect of the Inspector/Investigator portion of the Letter Of Understanding as found at page
190 of the collective agreement. Ultimately, I think it more likely than not that the parties would
have included Investigators in this part of the Letter if they intended to provide them with a
classification adjustment.
As stated above, it has not been established on a balance of probabilities that the
Investigators "should have been included in the classification adjustment for the
Administrative Category for the new Tax Auditor classifications standards", as claimed in the
56
grievance It follows that the grievors are not entitled to the remedy claimed For this reason,
it is unnecessary to address the classification argument presented by counsel for the
Employer However, without deciding the point, I make the following observations
(i) By way of the Letter Of Understanding, the parties agreed that
the Employer would develop a new Tax Auditor series 81d
class standards for positions of Tax Auditors in the Ministry of
Finance and would provide for a new salary range This case
is about whether the parties agreed to include Investigators,
classified at the level of Financial Officer 5, in this bargain I
am inclined to the opinion that I have jurisdiction to commence
an inquiry on this issue Put another way, I think that I could
properly determine if they were part of the deal,
(i i) The more problematic question is whether a monetary remedy,
of the type sought by the Union, could be awarded if I found that
the Investigators were entitled to inclusion in the Letter Of
Understanding Again, I am inclined to think that such a
remedy could be awarded without infringing sections 51 and
52 of the Crown Errployees Collective Bargaining Act. A
decision in the Union's favour would not be tantamount to this
Board creating a new classification or altering an existing one
The parties themselves did this by way of the Letter Of
Understanding Rather, such a decision would simply give
effect to the intention of the parties as reflected in their Letter
Of Understanding
After the movement of Tax Auditors into the Financial Officer series and the release of
the Alton et al decision, Investigators and Tax Auditors were both classified in the same
series, albeit atypically in the case of the latter, and paid at the same rate This equality of
treatment continued for many years until the Letter Of Understanding was implemented I also
note the evidence of Mr Stangarone to the effect that the Investigators may have a more
complex job than Tax Auditors
57
Given these factors, I can readily understand how these grievors may consider it unfair
that they not be included in the classification adjustment. In view of the fact that Revenue
Canada pays Investigators at a higher rate than does the Ministry of Finance, and the
evidence as to a recent shortage of Investigators, the Employer may wish to address the
issue of appropriate compensation so as to ensure it is able to retain and recruit competent
Investigators There is no doubt on the evidence that these employees have a key role in the
identification and prosecution of tax offenders
For all of the above reasons, the grievances are denied
Dated at Toronto, this 2nd day of April, 2001
Michael V Watters, Vice-Chair
58