New York Labor Law 740(1)(A)
Section 740(1)(a) defines an employee as "an individual who performs services for and under the control and direction of an employer for wages or other remuneration."
Like Labor Law 740, the definition of "employee" under Labor Law 741 includes the requirement that, inter alia, the "person who performs health care services for and under the control and direction of any public or private employer which provides health care services for wages or other remuneration."
The Court did not locate and the parties did not cite any reported caselaw defining remuneration under Labor Law 740(1)(a).
However, when determining whether an individual is an employee by virtue of the "remuneration" received, courts have acknowledged that remuneration need not be salary, but must consist of substantial benefits for the individual's work (see U.S. v. City of New York, 359 F3d 83  ("When analyzing whether individual is "employee" under Title VII, individual must first show she was hired by putative employer, and to do so, employee must prove that she received remuneration in some form for her work; such remuneration need not be salary but must consist of substantial benefits not merely incidental to the activity performed)).