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In the recent Federal Court Trial Division case of MNR v. HSBC BANK OF CANADA 2004 FC 467 the court held that CRA (the Canadian income tax department) had priority over the interest of a secured creditor that realized on its security at the time that a tax debtor owed source deductions.

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"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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