Ingrid C. Hutton

The bankrupt was ordered to pay child and spousal support to the Director of Maintenance Enforcement.

He later filed for bankruptcy and assigned his post-bankruptcy income tax refund to the trustee.

The Director filed a notice of continuing attachment against the federal Crown.

The Supreme Court of Canada held that the income tax refund constituted 'wages' under s. 68 of the Bankruptcy Act and did not automatically vest in the trustee under s. 67.

Furthermore, the assignment of the refund to the trustee was invalid under s. 67 of the Financial Administration Act.

Therefore, the Director's garnishment had priority.

The appellant appealed a decision of the Federal Court of Appeal which found its operations constituted a scheme of pyramid selling under the Combines Investigation Act and issued a prohibition order.

The Supreme Court of Canada dismissed the appeal, adopting the reasons of the Federal Court of Appeal.