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Director Liability and GST/HST Reassessments: Why Resignation and Delegation Failed

  • The Tax Court in Stevens v. The King addressed two key issues in GST/HST director liability: when a director’s resignation is legally effective for the two-year limitation period, and what is needed to prove due diligence.
  • The CRA assessed the taxpayer personally for over $700,000 in unremitted GST/HST; the taxpayer argued the assessment was time-barred because he had resigned, or alternatively that he had reasonably delegated tax duties.
  • The Court rejected both arguments, finding no reliable proof of a valid resignation and no credible evidence of active oversight or internal controls.
  • The decision reinforces that directors cannot avoid personal tax liability through informal resignations or passive reliance on others; strict statutory requirements apply.

Source: goodservicetax.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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