Glencore Canada Corporation v. FTI Consulting Canada Inc.
HST payable under the ETA is a tax debt owed to the Crown and collected by the supplier as agent/trustee; because the HST was not a liability owed to the supplier in its personal capacity (and s.224 did not apply as the supplier had not remitted), the mutuality requirement for contractual set-off was not met and Glencore could not set off HST against supplier liabilities; the supervising judge properly exercised her s.11 CCAA discretion to order Glencore to pay unpaid HST to the Receiver as agent for CRA, but it was unreasonable to require Glencore to pay interest and penalties assessed again…
Source excerpt
- Hst/gst
- Excise tax act
- Set-off (contractual and equitable)
- Companies' creditors arrangement act (s.11, s.21)
- Receivership
- Deemed trust