Markevich v. Canada, 2001 DTC 5305, 2001 FCA 144 -- summary under Section 222

Rothstein J.A. rejected the contention of the Minister that the Act was a complete code which provided for no limitation period in respect of collection procedures. Instead, Parliament's intention was that section 32 of the Crown Liability and Proceedings Act was to apply when Acts of Parliament (such as the Income Tax Act) were silent on the issue of limitations. Accordingly, the Minister was precluded by s. 3(5) of the Limitation Act (B.C.) from instituting collection proceedings against the taxpayer more than six year after the indebtedness of the taxpayer for federal and provincial income tax became collectible (i.e., six years after the expiry of the 90-day period referred to s. 225.1(1)).