In this 40-page decision, Justice Archambault says that a person who takes money as agent of a tax debtor does not get a transfer which CRA can attack. A principal does not transfer property to his agent. This is one of a series of cases in which Tax Court justices show their reluctance to allow CRA to collect money from people who never had any benefit from the transfer. (See e.g., para. 63.)
9101-2310 Quebec 2012cci (Archambault) — Deposits to an agent’s bank account are not transfers
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