Director liability assessment, s.227.1 ITA (source deductions)
CRA
Within 90 days
Needs prompt attention
- 90 days to file a Notice of Objection
- CRA must assess within 2 years of the director ceasing to hold office
- After the window: liens, bank freezes, garnishment, refund interception, Federal Court certificate
What this usually means
CRA is assessing a director personally for unremitted CPP, EI and income tax withheld from employees (trust amounts). CRA must show collection from the corporation is unlikely, then issues an NOA to the director.
What to gather
- The letter (all pages)
- Envelope and date received
- Account numbers (masked)
- Payroll journals
- T4 and T4A slips and summaries
- Remittance records
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