Baker – Tax Court of Canada notes that CRA assessed under s. 160 so as to give credit for Quebec tax paid under the Quebec equivalent

On the intestacy of her deceased brother, the taxpayer received property whose value was less than tax debts owing by him to CRA as well as to the ARQ. Smith J adverted to the fact that, technically, the taxpayer could have been assessed by each of CRA and the ARQ under s. 160 and its Quebec equivalent so that, depending on the numbers, she could have been assessed for taxes equalling double the value of the property devised to her. However, such double taxation did not arise here, as CRA only assessed for the difference between the value of her brother’s property received by her and the amount she paid to the ARQ.

Neal Armstrong. Summary of Baker v. The Queen, 2016 TCC 120 under s. 160(1).