I have posted here and here on the effect of the dissolution of a corporation and its subsequent revival on the liability of a director for source deductions and the like. The CRA has now weighed in with a technical interpretation on revival under the Ontario Business Corporations Act (the following quote is from the CCH Tax Window at ¶9835):
[T]he CRA stated that the only way that the directors may be assessed for income tax under the [Income Tax] Act is if an application is made to revive the corporation under the OBCA and the terms of the application provide that the corporation be reinstated retroactive to the date of its dissolution and that the directors be considered to have continued to hold office since the time prior to the dissolution.
