148. Liability for tax following winding-up

This section shall apply to a company which is wound up without having satisfied its tax liabilities, including any liability to withhold and remit tax,

A person who was a shareholder of the company at the time of the winding-up or during the preceding year shall be jointly and severally liable to pay the unpaid tax to the extent of a distribution of cash or property from the company received as a shareholder within one year prior to its winding-up.

A person liable for tax of a company under this section may invoke any rights as against the Department that would have been available to the company.