Priorities of Federal Tax Claims

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This paper provides a survey of case law on federal Crown priorities, with a particular emphasis on deemed-trust and enhanced garnishment mechanisms for source deductions and GST claims. Additional cases examining the “deemed security interest” and the “debts of equal degree” Crown prerogative are also discussed.

This paper is part of a collection presented at LESA’s Personal Property Security and Debt Recovery Essentials seminar in Edmonton on May 17, 2017 and in Calgary on May 24, 2017.

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