Why HST/GST and payroll arrears are the most urgent CRA debts
When you charge a customer HST/GST or withhold CPP, EI and tax from an employee’s pay, you’re collecting money that belongs to the Crown — effectively holding it in trust until you remit. If you don’t remit, CRA can assert a deemed trust over your assets for the unremitted amount, and that claim can take priority ahead of a secured lender.CRA Payroll source deductions are treated as the most serious of all.
The practical effect is that CRA tends to move faster and harder on these balances than on personal income tax, and lenders are especially wary of them. So if your arrears are HST/GST or payroll, don’t treat the timeline the way you might for an income-tax balance — treat it as shorter, and prioritize clearing it. The precise legal scope of deemed trust and any director liability is a matter for your tax lawyer; we coordinate the financing around that advice.
