Words and Phrases - "assets"
Industrial Development Bank v. Valley Dairy Ltd., 53 DTC 1027,  CTC 132 (Ont. S.C.)
S.112(6) of the Act as it read effective prior to July 1, 1950 provided that the liability of a taxpayer for amounts withheld by him "constituted a first charge on his assets", and s. 112(6) after that date provided that such amounts were a first charge "on his property". After finding that the Department had priority over a bank because the bank's floating charge had not become crystallized at the time the above statutory lien attached, Judson J. stated (p. 1028):
"If the floating charge had first become crystallized, I would have held that it had priority on the ground that 'property' or 'assets' means what is left to the taxpayer after satisfaction of prior charges."