A, who is indebted to each of CRA and Revenue Quebec (ARQ) for $50,000, transfers $10,000 of property to A's spouse (B) for no consideration. In response to a question as to whether CRA would reduce its assessment of B under s. 160 by the amount of the assessment made by ARQ under the equivalent Quebec provision, CRA stated that it did not have a policy to make such reduction, stating (TaxInterpretations translation):
In making an assessment by virtue of section 160, the Minister cannot make the assessment otherwise than in conformity with the authority conferred under the ITA.
An assessment under ETA s. 325 generally is to be reduced by the amount of the corresponding assessment under ITA s. 160, whereas there is no comparable reduction provision in s. 160 - so that double taxation can be avoided if the ETA assessment is issued second. CRA stated (TaxInterpretations translation):
In the situation where the two assessments are being dealt with at the same time, the administrative policy of the CRA is to issue the assessment under ETA section 325 last.