22 March 2006 External T.I. 2005-0133061E5 F - Limitation Period Collection of Debts -- summary under Subparagraph 222(4)(a)(ii)

The 10-year limitation period did not start running until March 4, 2004 respecting a tax debt that had arisen in 1998. Furthermore, having regard to Collins, s. 222(4) had retroactive effect, i.e., s. 224(a)(ii) applied to debts that had arisen prior to the enactment of that provision.