Rémillard v. The Queen, 2011 DTC 1286 [at at 1617], 2011 TCC 327 -- summary under Subparagraph 152(4)(a)(ii)

McArthur J. dismissed the taxpayer's argument that his waiver of the normal limitations period on reassessments applied only to the first reassessment issued beyond the limitations period and thus excluded the second. The words "at any time" in s. 152(4) mean "from time to time" and allow for multiple reassessments both inside and outside the limitations period. (Canada v. Agazarian, 2004 DTC 6366, 2004 FCA 32 at para. 33.)