Min. of Labour (Man.) v. The Queen in Right of Canada, 88 DTC 6514, [1988] 5 WWR 127 (Man QB), rev'd in part (1989), 59 DLR (4th) 34 (Man. C.A.) and (1989), 62 DLR (4th) 574 (Man. C.A.) -- summary under Subsection 227(5)

A statutory deemed trust created by s. 3(4) of the Payment of Wages Act (Manitoba), which provided that "every employer shall be deemed to hold the wages due or accruing due to an employee in trust for the employee ... whether or not the amount of the wages has been kept separate and apart by the employer" had priority over a s. 227(4) trust because it came into effect when the wages were due, whereas a s. 227(4) trust does not come into existence until an event of receivership.