Liability for tax following winding-up

—(1) This section applies to a company that is wound up without having satisfied its tax liabilities, including any liability to withhold and remit tax. (2) A person who was a shareholder of the company at the time of the winding-up, or during the preceding year, is jointly and severally liable to pay the unpaid tax, to the extent the shareholder received a distribution of cash or property from the company, within one year prior to its winding-up. (3) 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.