Unprecedented. Have you heard that word a lot in the past 4-5 months? Not surprisingly, the word ‘unprecedented’ is the default word to describe society’s reaction to COVID-19, its effects on our healthcare systems, our behaviours, our compliance (or not) with government directives and guidelines, and the impact to our economy and economic well-being. This is, in ...
The enforcement by Canada Revenue Agency (“CRA”) of its super priority position for deemed trust liabilities has long been an issue of uncertainty for secured creditors. While the Excise Tax Act (the “ETA”) has carved out “prescribed security interests” from that super priority, the calculation of the funds that continue to rank in priority to a prescribe ...
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