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  2. Apr 11, 2020 · CRA Super Priority Liens by Operation of Tax LawNo Registration Required. All of a taxpayer’s assets are deemed to be held in trust for the Crown if such a taxpayer fails to remit source deductions and/or GST/HST to CRA as and when required by the Income Tax Act and Excise Tax Act, respectively.

  3. Oct 2, 2022 · A CRA super priority lien is a claim on a debtors assets. It takes priority over any other interests in those assets, such as a mortgage. In practice, super priority liens apply to money that businesses owe the CRA for two specific things: GST/HST and payroll taxes (also called source deductions).

  4. May 10, 2019 · What Are Super Priorities? Super priorities are statutory liens and deemed trusts in favour of the Crown against real property of a person that rank in priority to other registered security interests – even though the Crown liens are not required to be registered.

  5. May 21, 2020 · Outside of certain types of insolvency proceedings and prescribed security interests, the CRAs deemed trust rights rank in priority to secured creditors. What you need to know. Secured creditors may be liable to repay the CRA amounts received from a borrower with an outstanding GST/HST liability.

  6. What is a Super Priority Lien? Pursuant to legislation*, governmental entities have the ability to claim a deemed trust that may have a super priority status over registered mortgages. This in essence permits the governmental entity to collect from a mortgage lender, the amounts owed by the borrower.

  7. Sep 7, 2022 · A CRA super priority lien is a claim on a debtors assets. It takes priority over any other interests in those assets, such as a mortgage. In practice, super priority liens apply to money that businesses owe the CRA for two specific things: GST/HST and payroll taxes (also called source deductions).

  8. Recent court cases have clarified Canada Revenue Agency (CRA) debts, including payroll and GST/HST remittances, are deemed trust debts — and these can have a super priority over the lender’s interest in the property.

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