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Tax law 2025 TCC 105

Astle v. The King

The Tax Court dismissed Kurtis Astle’s appeals, holding he remained liable as a director for unremitted source deductions and that the reassessments were timely.

  • Director liability
  • Due diligence (directors)
  • Statute of limitations (s.227.1(4))
  • Resignation effective date
  • Source deductions
  • Director-liability
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Tax law 2013 TCC 29

Chell v. The Queen

Appellant was a de facto director of both cDemo and Global within two years of the assessments because he continued to manage and act on behalf of the corporations and created the impression of directorship; he failed to exercise the required degree of care, diligence and skill (no oversight and improper delegation of remittance responsibilities), therefore the due diligence defence fails and the director's liability assessments are upheld.

  • Director's liability
  • Due diligence defence
  • De jure and de facto director
  • Resignation effective date
  • Remittance of source deductions and gst
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Canada decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.