In Canada (Attorney General) v 18335898 Alberta Ltd (Whitecap Energy Inc), 2023 ABKB 357, the taxpayer wound-up and dissolved in 2020. All of its assets were transferred to its parent. The CRA audited the taxpayer’s 2017 and 2018 taxation years. The Attorney General of Canada then sought to revive the taxpayer so that the CRA could reassess it. The Court granted the revival on the basis that, while the Attorney General was not yet a creditor of the taxpayer because an assessment had not yet been issued (a dubious proposition), the Attorney General was an “interested person” under the relevant provisions of the Alberta Business Corporations Act.
