What is a Deemed Trust?

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In a bankruptcy, amounts owing for GST/HST and the employer portion of CPP and EI, and penalties and interest on these amounts are unsecured claims, ranking the same as all other general creditors of a debtor. However, before bankruptcy occurs, CRA may obtain a lien or charge (be filing a memorial judgment) against the real or personal property of a debtor, CRA will be a secured creditor.