Tax court considers a novel issue: combination of s. 160, a waiver, and the Interpretation Act

By Cris Best (February 15, 2024, 12:13 PM EST) -- A common issue in the practice of tax law is the derivative liability tax assessment, in this case pursuant to s. 160 of the Income Tax Act, RSC 1985, c 1 (5th Supp). In short, if a taxpayer with a tax debt transfers property to a third party, under certain circumstances, Canada Revenue Agency (CRA) can assess that party to satisfy the debt of the transferor....