CRA acknowledges that the deemed trust for unpaid GST/HST (or source deductions) does not follow assets in an arm’s length sale

CRA (contrary to alleged practices of some of its collection agents) recognizes that the deemed trust under ETA s. 222(3) over assets of a tax debtor continues to apply, after an arm’s length sale of those assets, to the sales proceeds rather than to the sold assets, so that the arm’s length purchaser should not have to worry about the deemed trust attaching to the purchased assets.

ITA s. 227(4.1) is quite similar, so that the same position should apply where the vendor has unremitted source deductions.

Neal Armstrong. Summary of CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 3 under ETA, s. 222(3).