In a rare move, the Supreme Court of Canada has allowed the Callidus Capital Corporation appeal from the bench. This appeal involved the priority between secured creditors and the Canada Revenue Agency under the Excise Tax Act once a tax debtor declares bankruptcy. This is a welcome decision from the Supreme Court of Canada for taxpayers. A summary of the Federal Court of Appeal decision (which was reversed by the SCC) can be found here. The Sales Tax, Customs & International Trade group of Miller Thomson LLP will provide a full analysis on the judgment once it has been released.
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