Liability of estate controllers: managers and trustees are liable for GST tax obligations and recoveries as if they were the taxpayer. Where an estate of a taxable person is under the control of a Court of Wards, Administrator General, Official Trustee, receiver or manager (including any person who in fact manages the business), that controller is liable for tax, interest and penalty arising under the GST law and such liabilities shall be levied upon and recovered from the controller in the same manner and to the same extent as from the taxable person as if he were conducting the business himself, with all applicable statutory and rule-based provisions applying accordingly.