Can CRA collection agents apply ETA s. 222(3) (similar to ITA s. 227(4.1)) to pursue arm's length purchasers of the assets of a tax debtor? Before referring to the non-arm's length rule in ETA s.325 (similar to ITA s. 160), CRA stated:
[T]he deemed trust [under s. 222(3)] does not attach to any particular property. Rather, it is similar to a floating charge over all of the property of the person. Consequently, the person is free to sell or otherwise transfer property in the ordinary course of business. Where the person sells or transfers property, the deemed trust will detach from the property and attach to the proceeds of the sale or transfer.