The appellants challenged the constitutionality of sections 224(1.2) and (1.3) of the Income Tax Act, arguing that the provisions for seizing funds owing by a tax debtor and giving priority over provincial security interests infringed on the provincial jurisdiction over property and civil rights.
The Supreme Court of Canada dismissed the appeal, adopting the reasons of the Saskatchewan Court of Appeal, and held that the provisions were not ultra vires the Parliament of Canada.
