Section 221P presents considerable difficulties of construction, but in my opinion it was intended that that section, read with the definition of trustee in s. 6, should have the effect that a receiver appointed under a deed which created a floating charge over all the assets of the company giving it is a trustee and liable under s. 221P, although only to the extent of the assets which passed under his control. The definition of "trustee" will, unless the contrary intention appears, apply to s. 221P and if it applies will render that section applicable to the case of a receiver. It does not seem to me that s. 221P reveals an intention to exclude the definition; the fact that sub-s. (3) deals with the costs, charges and expenses of administration or winding up, payable by the trustee of the estate of a bankrupt or the liquidator of a company, but does not similarly deal with the costs of a receivership, does not in my opinion indicate that the section is not intended to have any application to receivers. It may be assumed that s. 221P contemplates a general vesting of property in the trustee, and that the section is therefore not intended to apply to the case where a mortgage under which a receiver is appointed charges part only of the employer's property. However, it is difficult to accept that the section is intended only to apply if literally every item of property belonging to the employer vests in, or passes under the control of, the trustee, because if that were its effect the section would not in every case apply to a trustee in bankruptcy, since in a particular case there may be a residue of the bankrupt's property which will not vest in the trustee: ss. 5 (the property of the bankrupt), 58, 116 ofthe Bankruptcy Act 1966 Cth, and see Stapleton v. Federal Commissioner of Taxation [22] . However, it is clearly the intention of the Parliament that the section applies to every trustee in bankruptcy: s. 109(1) of the Bankruptcy Act 1966. But even if it be accepted that "his property" in s. 221P means "all his property", it seems to me that in the present case the control of all the property of the company, within the meaning of the section, did pass to the receiver. It is perfectly true that the company had an equitable interest in the property with which the receiver could not deal and which did not pass into his control, so that technically it can be said that the company had an interest in the property which did not pass under the control of the receiver. However, from a practical or commercial point of view it seems to me natural to describe the effect of the deed as being that all of the property of the company passed under the control of the receiver notwithstanding that the company retained an equitable interest in it. The control of all the company's assets passed to the receiver, although if the amounts secured were paid in full any surplus resulting from the realization would belong to the company. In fact of course the equitable interest of the company was valueless, and that is sufficient reason to ignore it. In my opinion the inclusion of "receiver" in the definition of trustee, the fact that s. 221P includes trustees in whom the property is not vested, and the reference to secured debts in sub-s. (2), all indicate that the section was intended to apply to a receiver under a deed of mortgage or charge. Sub-section (2) could not possibly be construed so as to enable a trustee who held property subject to a mortgage in favour of some person other than the employer to pay the Commissioner out of the interest of that third person, and if it does not apply to a case such as the present the reference to secured debts would appear to be meaningless.