Cases
Groulx v. Canada, 2010 DTC 5027 [at at 6621], 2010 FCA 321
In challenging a set-off under s. 224.1 of a tax debt of the taxpayer against 30% of Canada Pension Plan and Old Age Security payments receivable...
Mintzer v. The Queen, 96 DTC 6027, [1996] 1 CTC 249 (FCA)
A prohibition under the Canada Pension Plan Act against the attachment, or the seizure and execution, of Canada Pension Plan payments did not...
Clarkson Co. Ltd. as Receiver and Manager of Aero Trades (Western) Ltd. v. The Queen, 89 DTC 5050, [1989] 1 CTC 142 (FCA)
The Crown was entitled to set-off taxes owing by the taxpayer only against debts owing by the Crown to the taxpayer (in respect of air carrier...
See Also
La Banque Canadienne Nationale v. The Queen, 79 DTC 5178, [1979] CTC 165 (FCTD)
The effect of an assignment of accounts receivable under section 88 (now section 178) of the Bank Act was not to make the bank the creditor of the...
Administrative Policy
IC98-1R4 "Tax Collections Policies" 12 June 2013
We can offset (apply against another debt) your repayment or refund to debts for which you are liable. However, for debts that relate to the...
Articles
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper
Limitations on CRA compensation (set-off) rights (p. 13:36)
While Revenu Québec followed the decision in DIMS Construction [fn 111: …2005 SCC...