In this episode of the Friedlan Law Podcast find out about the recent decision of the Federal Court of Appeal in Canada v. Colitto, 2020 FCA 70. The decision of the Federal Court of Appeal overturned the decision of the Tax Court and the victory of the taxpayer. The central question of this case is when an assessment under paragraph 227.1(1) of the Income Tax Act, which relates to directors liability, crystallizes, such that it can give rise to a derivative assessment under Section 160.