Peter Kirkwood Holdings Ltd. v. Canada, 2004 DTC 6035, 2003 FCA 481 -- summary under Section 32

In rejecting a submission that the Minister was statute barred from proceeding against the taxpayer because of the expiry of the two-year limitation period provided in the Limitations Act (Ontario), Nadon J.A.stated (at p. 6035) that "in The Queen v. Markevich, 2003 DTC 5185 the Supreme Court of Canada made it clear that tax debts created under the Income Tax Act were not subject to provincial limitation".