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Published: March 11, 2020

Last Updated: March 16, 2020

Subsection 227.1(4) of the Canadian Income Tax Act provides that no action for director liability for unpaid source deductions of a corporation may be commenced more than 2 years after a director ceased to be a director of the corporation. This means that CRA has 2 years to issue an income tax assessment for director income tax liability. Our experienced Ontario income tax lawyers often avoid director income tax liability using this 2 year limitation period.


"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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