How have the two Appellants dealt with long-delayed payments under the Goods and Services Tax (SD) Act?

The overdue SD payments go back to April 1999. During the period of April to November, they were either paid in whole (May and July), partially (April, June and August), or not at all (September and October). Once the Appellants were made aware of the situation, at the beginning of November, the November and December SD payments were made in whole. Efforts were made from this time on to rectify or fix the situation. I am not stating this fact to show the degree of responsibility the two Appellants took once they were aware of the overdue payments, since these delayed measures are irrelevant and do not respond to the standard of diligence set out in the Act. I refer to Trann v. Canada, [2004] F.C.A. 138, at paragraph 11: The Applicant, as sole director and manager had the responsibility to ensure that the remittances were made. His belated attempts to remedy the situation subsequent to the failure to remit the GST funds as they became due are not sufficient to meet the due diligence test in the Act.