Caveat Creditor: When CRA Deemed Trusts Outrank a Mortgage

It has been said that nothing in this world is certain, other than death and taxes. Whether any given tax is ‘certain’ can be debated (our tax team is here to help), but the Federal Court of Appeal has weighed in on the priority of certain tax claims in Toronto-Dominion Bank v. Canada, 2020 FCA […]

The Taxman Cometh: CRA Priorities in Insolvency Proceedings

Courts and lawmakers often refer to Canada Revenue Agency (“CRA”) as an involuntary creditor when businesses fail to make required tax payments to the governmental authority. The timely collection of taxes and payroll deductions also plays a fundamental role in the financing of government.