CVH Investments Ltd. v. Minister of National Revenue

CVH Investments Ltd. v. Minister of National Revenue

The Court held that s.224(1.2) of the Income Tax Act gives the respondent priority over the appellant's unsecured interests; the wrong‑party complaint could not be considered on appeal because it was not raised below and the factual record is inadequate; the respondent's failure to pursue its claim in the bankruptcy...

Source-derived case information.

Citation
C28072
Parties
Appellant: CVH Investments Ltd.; Respondent: The Minister of National Revenue
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
30 April 1999
Procedural Posture
Civil Appeal Tax/collection / Court of Appeal Decision on Appeal From Trial Judgment Dated August 29, 1997
Outcome
Appeal dismissed with costs.
Legal Topics
Income Tax Act S.224(1.2), Priority of Crown for Source Deductions, Assessment Against Wrong Party, Bankruptcy Claims and Assessments, Employer Source Deductions
Source Language
en
Tax Law Bankruptcy Law Civil Procedure Income Tax Act S.224(1.2) Priority of Crown for Source Deductions Assessment Against Wrong Party Bankruptcy Claims and Assessments Employer Source Deductions

Source-derived case record

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Parties

CVH Investments Ltd.

Appellant

The Minister of National Revenue

Respondent

Procedural Posture

Civil Appeal Tax/collection / Court of Appeal Decision on Appeal From Trial Judgment Dated August 29, 1997

  1. 1 Whether the tax assessment was made against the correct party (whether the bankrupt was the employer)
  2. 2 Whether s.224(1.2) of the Income Tax Act gives the Crown priority over the appellant's unsecured interests
  3. 3 Whether the respondent's failure to pursue its claim in the bankruptcy proceedings prevents it from proceeding with its assessment

Ratio Decidendi

The Court held that s.224(1.2) of the Income Tax Act gives the respondent priority over the appellant's unsecured interests; the wrong‑party complaint could not be considered on appeal because it was not raised below and the factual record is inadequate; the respondent's failure to pursue its claim in the bankruptcy did not bar the assessment. The appeal was dismissed with costs.

Court Disposition

Appeal dismissed with costs.

Orders

  • Appeal dismissed with costs.