After noting that the University of Waterloo and Human Resources and Development Canada had failed to withhold Part XIII tax on pension income and Canada Pension Plan and Old Age Security payments made to the taxpayer, Miller J. stated (at para. 9):
"Subsection 215(6) does not shift a tax burden to the University of Waterloo and the HRDC. The University of Waterloo and the HRDC are liable for the tax they failed to deduct; however, this does not aid Mr. Soloman as both entities can recover the taxes from him."