Canada v. Barrett, 2012 FCA 33, is an interesting companion to Madison v R, 2012 FCA 80 (discussed here). The upshot of Barrett is that the CRA need not undertake reasonable collection efforts against a corporation before assessing one of its directors for unremitted GST. The CRA need only act in good faith when directing an execution against the corporation. Barrett, then, continues a trend begun by the Federal Court of Appeal in Madison that makes it easier for the CRA to pursue a director for unremitted “source deductions” or HST.
