Date: 20020410
Docket: T-1881-01
Neutral Citation: 2002 FCT 401
Toronto, Ontario, Wednesday, the 10th day of April, 2002
PRESENT: THE HONOURABLE MADAM JUSTICE DAWSON
BETWEEN:
GLENN ALEXANDER ROSS
Applicant
- and -
HER MAJESTY THE QUEEN
IN RIGHT OF CANADA
Respondent
REASONS FOR ORDER AND ORDER
[1] The issue raised on this application for judicial review is whether on May 16, 2001, by application of certain limitation provisions, the Canada Customs and Revenue Agency ("CCRA") was out of time to issue a Requirement to Pay ("Requirement") in respect of a tax debt owed by Mr. Ross, the applicant in this proceeding.
THE FACTS
[2] At all relevant times Mr. Ross has been resident in British Columbia.
[3] On or about May 25, 1993, Revenue Canada, the predecessor to the CCRA, issued notices of reassessment to Mr. Ross in respect of the 1989 and 1990 taxation years. Mr. Ross filed notices of objection in respect of those assessments, but on January 3, 1995 the assessments were confirmed. While he was entitled to appeal those decisions to the Tax Court, Mr. Ross filed no appeal.
[4] By application of subsection 225.1(1) of the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1 ("Act") Revenue Canada was therefore at liberty to commence collection activities with respect to Mr. Ross' indebtedness in respect of the 1989 and 1990 tax years as of April 3, 1995.
[5] On September 30, 1999, a certificate in respect of this debt was registered in this Court as authorized by section 223 of the Act. Also on September 30, 1999, a writ of seizure and sale was issued by the Court. On October 7, 1999, the debt was registered in the British Columbia Personal Property Registry.
[6] On May 16, 2001, CCRA issued a Requirement to Mr. Ross' wife in an effort to collect the monies owed to it by Mr. Ross. The Requirement alleged that Mr. Ross was indebted to the CCRA in the amount of $139,530.48.
[7] Mr. Ross denied, and continues to deny, liability in that amount on the ground that the debt has been statutorily extinguished by operation of subsection 9(1) of the Limitation Act, R.S.B.C. 1996, c.266 ("Limitation Act"). Parenthetically, it should be noted that at the hearing it was common ground between Mr. Ross and the Crown that Mr. Ross properly owes the sum of $250.00 to the CCRA in respect of a Heating Rebate issued in January, 2001. The balance of the claimed indebtedness is agreed to arise in respect of the 1989 and 1990 taxation years. In these reasons, the word "debt" will be used to mean the monies owing in respect of the 1989 and 1990 years, exclusive of the sum of $250.00 and any interest attributable thereto.
[8] This application for judicial review is brought "in respect of a decision of the Minister of National Revenue ["Minister"] which was communicated on May 16, 2001 in a Requirement to Pay [...] wherein it is claimed that the applicant is indebted to the respondent in the total amount of $139,530.48". The relief sought is as follows:
(a) an order, pursuant to sections 18 and 18.1 of the Federal Court Act:
(i) declaring invalid, quashing or setting aside the said decision of the Minister;
(ii) declaring that the applicant is not indebted to the respondent for the applicant's 1990 and prior taxation years;
(iii) prohibiting the Minister from taking any steps to collect amounts not due and owing by the applicant to the respondent;
(iv) directing the Minister to redetermine the amount due and owing by the applicant to the respondent on the basis that the applicant's debt for income taxes as at May 1, 1995 was nil;
(v) declaring invalid, quashing or setting aside certificate ITA-8972-99 issued by the Minister against the applicant on September 30, 1999;
(vi) declaring invalid, quashing or setting aside the WRIT OF SEIZURE AND SALE issued at the request of the Minister on September 30, 1999 by the Registry Officer, Federal Court - Trial Division against the applicant;
(vii) declaring invalid or unlawful, quashing or setting aside the REQUIREMENT TO PAY issued by the Minister through the Canada Customs and Revenue Agency, on May 16, 2001 to Heather Petrea Ross-Siemens in respect of the alleged tax debt of the applicant; and
(viii) compelling the registrar of the British Columbia personal property registry to discharge the base registration # 8501434 filed on October 7, 1999 by the Minister in respect of certificate ITA-8972-99.
(b) costs.
ANALYSIS
[9] Consideration of whether the debt has been extinguished begins with the decision of the Federal Court of Appeal in Markevich v. Canada, [2001] 3 F.C. 449; 2001 FCA 144, leave to appeal to the Supreme Court of Canada granted [2001] S.C.C.A. No. 371. Mr. Ross relies upon Markevich. The Crown, prosecuting its appeal in Markevich, acknowledges the decision to be binding upon this Court.
[10] Mr. Markevich was a resident of British Columbia who, as of June, 1986, had a total liability for federal and provincial income tax of $234,136.04. In January, 1998, Mr. Markevich was advised that the Minister intended to take collection action for the full amount of the indebtedness. Mr. Markevich challenged the Minister's right to so proceed and the Federal Court of Appeal held that by virtue of the combined effect of section 32 of the Crown Liability and Proceedings Act, R.S.C. 1985, c. C-50 ("CLPA") and subsection 3(5) of the Limitation Act, the
Minister was statute-barred from collecting the amount owing, whether by court action or statutory collection procedures.
[11] As to the nature of this type of indebtedness and permitted collection methods, the Act provides in section 222 that monies owing in respect of taxes, interest, penalties, costs and the like are debts due to Her Majesty and are recoverable as such in the Federal Court, or any court of competent jurisdiction, or in any other manner provided by the Act.
[12] As to the timing of collection efforts, section 225.1 of the Act prohibits the Minister from effecting collection until the happening of certain events. The limit relevant in this case is found in subsection 225.1(2) which precludes collection activity until 90 days after the notice was mailed to Mr. Ross advising him that the re-assessments were confirmed.
[13] Thereafter, the following provisions of the Act deal with collection proceedings both in Court and through the Minister's statutory authority.
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223. (1) For the purposes of subsection 223(2), an "amount payable" by a person means any or all of
(a) an amount payable under this Act by the person;
(b) an amount payable under the Employment Insurance Act by the person;
(b.1) an amount payable under the Unemployment Insurance Act by the person;
(c) an amount payable under the Canada Pension Plan by the person; and
(d) an amount payable by the person under an Act of a province with which the Minister of Finance has entered into an agreement for the collection of taxes payable to the province under that Act.
(2) An amount payable by a person (in this section referred to as a "debtor") that has not been paid or any part of an amount payable by the debtor that has not been paid may be certified by the Minister as an amount payable by the debtor.
(3) On production to the Federal Court, a certificate made under subsection 223(2) in respect of a debtor shall be registered in the Court and when so registered has the same effect, and all proceedings may be taken thereon, as if the certificate were a judgment obtained in the Court against the debtor for a debt in the amount certified plus interest thereon to the day of payment as provided by the statute or statutes referred to in subsection 223(1) under which the amount is payable and, for the purpose of any such proceedings, the certificate shall be deemed to be a judgment of the Court against the debtor for a debt due to Her Majesty, enforceable in the amount certified plus interest thereon to the day of payment as provided by that statute or statutes.
(4) All reasonable costs and charges incurred or paid in respect of the registration in the Court of a certificate made under subsection 223(2) or in respect of any proceedings taken to collect the amount certified are recoverable in like manner as if they had been included in the amount certified in the certificate when it was registered.
Charge on property
(5) A document issued by the Federal Court
evidencing a certificate in respect of a debtor registered
under subsection 223(3), a writ of that Court issued
pursuant to the certificate or any notification of the
document or writ (such document, writ or notification in
this section referred to as a "memorial") may be filed,
registered or otherwise recorded for the purpose of
creating a charge, lien or priority on, or a binding interest
in, property in a province, or any interest in such property,
held by the debtor in the same manner as a document
evidencing
(a) a judgment of the superior court of the province
against a person for a debt owing by the person, or
(b) an amount payable or required to be remitted by a
person in the province in respect of a debt owing to
Her Majesty in right of the province
may be filed, registered or otherwise recorded in
accordance with or pursuant to the law of the province to
create a charge, lien or priority on, or a binding interest in,
the property or interest. --
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223. (1) Pour l'application du paragraphe (2), le montant payable par une personne peut être constitué d'un ou plusieurs des montants suivants:
a) un montant payable par elle en application de la présente loi;
b) un montant payable par elle en application de la Loi sur l'assurance-emploi;
b.1) un montant payable en application de la Loi sur l'assurance-chômage;
c) un montant payable par elle en application du Régime de pensions du Canada;
d) un montant payable par elle en application d'une loi provinciale et que le ministre doit recouvrer aux termes d'un accord conclu par le ministre des Finances pour le recouvrement des impôts payables à la province en vertu de cette loi.
(2) Le ministre peut, par certificat, attester qu'un montant ou une partie de montant payable par une personne - appelée "débiteur" au présent article -- mais qui est impayé est un montant payable par elle.
(3) Sur production à la Cour fédérale, un certificat fait en application du paragraphe (2) à l'égard d'un débiteur est enregistré à cette cour. Il a alors le même effet que s'il s'agissait d'un jugement rendu par cette cour contre ledébiteur pour une dette du montant attesté dans le certificat, augmenté des intérêts courus jusqu'à la date du paiement comme le prévoit les lois visées au paragraphe (1) en application desquelles le montant est payable, et toutes les procédures peuvent être engagées à la faveur du certificat comme s'il s'agissait d'un tel jugement. Dans le cadre de ces procédures, le certificat est réputé être un jugement exécutoire rendu par cette cour contre le débiteur pour une dette envers Sa Majesté du montant attesté dans le certificat, augmenté des intérêts courus jusqu'à la date du paiement comme le prévoit ces lois.
(4) Les frais et dépens raisonnables engagés ou payés en vue de l'enregistrement à la Cour fédérale d'un certificat fait en application du paragraphe (2) ou de l'exécution des procédures de recouvrement du montant attesté dans le certificat sont recouvrables de la même manière que s'ils avaient été inclus dans ce montant au moment de l'enregistrement du certificat.
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(5) A document issued by the Federal Court evidencing a certificate in respect of a debtor registered under subsection 223(3), a writ of that Court issued pursuant to the certificate or any notification of the document or writ (such document, writ or notification in this section referred to as a "memorial") may be filed, registered or otherwise recorded for the purpose of creating a charge, lien or priority on, or a binding interest in, property in a province, or any interest in such property, held by the debtor in the same manner as a document evidencing
(a) a judgment of the superior court of the province against a person for a debt owing by the person, or
(b) an amount payable or required to be remitted by a person in the province in respect of a debt owing to Her Majesty in right of the province
may be filed, registered or otherwise recorded in accordance with or pursuant to the law of the province to create a charge, lien or priority on, or a binding interest in, the property or interest.
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(5) Un document délivré par la Cour fédérale et faisant preuve du contenu d'un certificat enregistré à l'égard d'un débiteur en application du paragraphe (3), un bref de cette cour délivré au titre du certificat ou toute notification du document ou du bref (ce document ou bref ou cette notification étant appelé "extrait" au présent article) peut être produit, enregistré ou autrement inscrit en vue de grever d'une sûreté, d'une priorité ou d'une autre charge un bien du débiteur situé dans une province, ou un droit sur un tel bien, de la même manière qui peut l'être, au titre ou en application de la loi provinciale, un document faisant preuve:
a) soit du contenu d'un jugement rendu par la cour supérieure de la province contre une personne pour une dette de celle-ci;
b) soit d'un montant payable ou à remettre par une personne dans la province au titre d'une créance de Sa Majesté du chef de la province.
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224. (1) Where the Minister has knowledge or suspects that a person is, or will be within one year, liable to make a payment to another person who is liable to make a payment under this Act (in this subsection and subsections 224(1.1) and 224(3) referred to as the "tax debtor"), the Minister may in writing require the person to pay forthwith, where the moneys are immediately payable, and in any other case as and when the moneys become payable, the moneys otherwise payable to the tax debtor in whole or in part to the Receiver General on account of the tax debtor's liability under this Act.
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224. (1) S'il sait ou soupçonne qu'une personne est ou sera, dans les douze mois, tenue de faire un paiement à une autre personne qui, elle-même, est tenue de faire un paiement en vertu de la présente loi (appelée "débiteur fiscal" au présent paragraphe et aux paragraphes (1.1) et (3)), le ministre peut exiger par écrit de cette personne que les fonds autrement payables au débiteur fiscal soient en totalité ou en partie versés, sans délai si les fonds sont immédiatement payables, sinon au fur et à mesure qu'ils deviennent payables, au receveur général au titre de l'obligation du débiteur fiscal en vertu de la présente loi.
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[14] The limitation provisions considered by the Federal Court of Appeal in Markevich, supra, and relied upon by Mr. Ross, are section 32 of the CLPA and subsections 3(5) and 9(1) of the Limitation Act. They, respectively, provide as follows:
The Crown Liability and Proceedings Act
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32. Except as otherwise provided in this Act or in any other Act of Parliament, the laws relating to prescription and the limitation of actions in force in a province between subject and subject apply to any proceedings by or against the Crown in respect of any cause of action arising in that province, and proceedings by or against the Crown in respect of a cause of action arising otherwise than in a province shall be taken within six years after the cause of action arose.
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32. Sauf disposition contraire de la présente loi ou de toute autre loi fédérale, les règles de droit en matière de prescription qui, dans une province, régissent les rapports entre particuliers s'appliquent lors des poursuites auxquelles l'État est partie pour tout fait générateur survenu dans la province. Lorsque ce dernier survient ailleurs que dans une province, la procédure se prescrit par six ans.
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The Limitation Act
3(5) Any other action not specifically provided for in this Act or any other Act may not be brought after the expiration of 6 years after the date on which the right to do so arose.
[...]
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9(1) On the expiration of a limitation period set by this Act for a cause of action to recover any debt, damages or other money, or for an accounting in respect of any matter, the right and title of the person formerly having the cause of action and of a person claiming through the person in respect of that matter is, as against the person against whom the cause of action formerly lay and as against the person's successors, extinguished.
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[15] In Markevich, Justice Rothstein, writing for the Court, considered the scope of the phrase "proceedings [...] in respect of any cause of action" found in section 32 of the CLPA, and considered whether it applies to the Minister's statutory collection procedures under the Act. At paragraph 51 Justice Rothstein wrote:
Statutory collection procedures parallel court proceedings after a judgment is obtained. By enacting the statutory collection procedures under the Income Tax Act, Parliament gave the Minister direct access to enforceable collection procedures that would otherwise only be available after a court action and judgement. The issuance of a requirement to pay by the Minister has substantially the same effect as a garnishing order issued by the Court. It binds a third party debtor to pay to the Crown amounts to which the taxpayer is entitled from that third party. A direction to seize and sell chattels is analogous to a writ of execution issued by a court. In fact, subsection 225(5) provides that such goods and chattels that would be exempt from seizure under a writ of execution issued out of a superior court of the province in which the seizure is made are exempt from seizure by the Minister. To construe the term "proceedings" in section 32 as including these procedures, it seems to me, recognizes the substantial similarity between statutory and court collection procedures.
[16] At paragraphs 65 and 66 Justice Rothstein continued:
I conclude therefore that proceedings brought by the Crown in respect of a cause of action in section 32 of the Crown Liability and Proceedings Act include both court and statutory collection procedures under the Income Tax Act. The applicable limitation provision is subsection 3(5) of the British Columbia Limitation Act. Under subsection 3(5), an action may not be brought after the expiration of six years after the date on which the right to do so arose. Action is defined as including a self help remedy. Its scope is obviously intended to be broad and not limited to a court action.
The statutory collection procedures under the Income Tax Act are available to the Minister in his own right, exercisable by himself alone, without the necessity of court action. I have no difficulty concluding that statutory collection procedures under the Income Tax Act are self help remedies for purposes of subsection 3(5) of the British Columbia Limitation Act. In any event, by subsection 9(1) of the Limitation Act, after expiry of the relevant limitation period, the cause of action is extinguished.
[17] The predominant feature before the Court in Markevich, supra, was that from 1987 to 1998 Revenue Canada took no steps to collect the debt. Thus, the Federal Court of Appeal had to address the question of whether the Crown might pursue collection of tax debts indefinitely, despite prolonged inaction.
[18] That is not the fact situation now before the Court because within what the Federal Court of Appeal found to be the applicable six-year limitation period the Crown took steps to collect the debt. The Minister filed a certificate in respect of the debt in this Court, obtained a writ of seizure and sale, and registered the debt in the applicable personal property registry.
[19] Mr. Ross argues, however, that those actions do not avail the Minister because the Requirement was issued beyond the applicable six-year limitation period. The parties agree that by application of the principles articulated in Markevich, the limitation period commenced running on April 3, 1995 and so had expired on April 4, 2001.
[20] Mr. Ross says that the filing of the certificate did not protect the Minister's position because:
1. The Minister' s certificate is not a judgment of this or any Court. The making of a certificate is simply an exercise of statutory authority. To protect against the limitation period the Minister should have commenced proceedings in the Court in respect of the tax debt. This is said to be reflected in the fact that Rule 425(a) of the Federal Court Rules, 1998 ("Rules") provides:
| 425. An order for the payment of money may be enforced by
(a) a writ of seizure and sale in Form 425A.
(Underlining added)
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425. L'exécution forcée de l'ordonnance exigeant le paiement d'une somme d'argent se fait par l'un des moyens suivants :
a) bref de saisie-exécution établi selon la formule 425A.
(Soulignement ajouté)
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Mr. Ross submits that there is no "order" to support the writ because the certificate is not an order. If the certificate is an order, Mr. Ross argues that he should have been served with it on its filing and should have been able to "mount a defense" to it.
2. The writ of seizure and sale "is fruit of the same poison tree that gave life to the certificate". It would be anomalous if the effect of obtaining and registering the writ would be to allow enforcement proceedings to continue more than six years after the debt became collectible. All enforcement efforts must cease after six years, unless a judgment has been obtained as defined in the Limitation Act.
3. The limitation period provided in the Limitation Act with respect to judgments does not apply because the certificate does not fall within the definition of "judgment" in the Limitation Act.
[21] In advancing these arguments Mr. Ross relies upon authority such as the Minister of National Revenue v. Bolduc, [1961] Ex. C.R. 115; The Queen v. Star Treck Holdings Limited, [1978] 1 F.C. 61 (T.D.); Her Majesty the Queen v. T.H. Parker (1981), 2 C.E.R. 181 (F.C.T.D.); and E.H. Price Limited v. The Queen, [1983] 2 F.C. 841 (F.C.A.), all to the effect that a certificate is not a judgment of this Court.
[22] Although expressed in different fashions, the linch-pin of Mr. Ross' position is that the effect of filing the Minister's certificate is so different qualitatively from that of obtaining a judgment that filing a certificate is ineffective to preserve the Minister's rights.
[23] With respect to this position, it is correct that in the context of issues such as how a certificate may be attacked or amended, the Court has stated in the authorities cited by Mr. Ross that a certificate is not, and does not become, a judgment of the Court. But the Court has also in those same cases held that the effect of the making and the registration of a certificate is precisely as is stated in the Act. In the words of Justice Thurlow, as he then was, in Bolduc, supra at page 118, registration of a certificate "has the same force and effect and the same proceedings may be taken upon it as if it were a judgment".
[24] This means that upon registration of the certificate within six years of the commencement of the limitation period, the certificate was capable of supporting the issuance of writs of execution pursuant to Rule 434(1).
[25] While it is true that there is no "order" in the sense of a judgment rendered in a contested proceeding in this Court between Mr. Ross and the Crown, the wording of subsection 223(3) of the Act makes such order unnecessary because through this provision Parliament has made clear its intent that the certificate "has the same effect" of "a judgment obtained in the Court" and all proceedings may be taken on the basis of the certificate as if it were a judgment of the Court.
[26] The answer to Mr. Ross' concern that he should have been notified of the filing of the certificate and given an opportunity to defend his position or appeal the certificate is found in subsection 165(1) of the Act, which requires that a taxpayer challenge the Minister's assessment within 90 days, and in subsection 169(1) of the Act, which requires that an appeal to the Tax Court be brought within 90 days of confirmation by the Minister of an assessment or re-assessment. See: Olympia Interiors Ltd. v. Canada, 2001 F.C.A. 360 at paragraph 5, and 2001 F.C.A. 361 at paragraph 6. Here, no appeal was taken to the Tax Court from the confirmation of the notices of assessment. That was the proper forum for attacking the propriety of the debt.
[27] The above analysis deals with the Minister's right to take proceedings on the certificate pursuant to section 223 of the Act. Given the determination of the Federal Court of Appeal in Markevich, supra, that the limitation period also applies to the statutory collection proceedings, I have considered whether the Minister may pursue those remedies more than six years after the debt accrued where a certificate has been filed within the six-year period.
[28] At first blush there may seem little to connect filing a certificate in the Court with preservation of the Minister's right to exercise her statutory collection procedures.
[29] Counsel for the Minister submits that the answer is found in the wording of subsection 224(1) of the Act which allows the Minister to issue a requirement to pay where it is known or suspected that within one year a third party will be liable to make a payment to a person "who is liable to make a payment under" the Act. Because the effect of the filing of the certificate makes a person liable to execution, it is submitted that such person continues to be "liable to make a payment under this Act".
[30] I have been persuaded that this submission is correct for the following reasons.
[31] First, the effect of Markevich is that the limitation period provided in section 32 of the CLPA is applicable to both statutory collection procedures and court collection procedures, and that after the expiry of the relevant limitation period the cause of action is extinguished. This requires the Minister to take remedial steps to collect a tax debt within the limitation period. Markevich does not require the Minister to obtain a judgment of the Court to preserve her rights, nor does Markevich require the Minister to exhaust all collection efforts within the limitation period. Markevich recognizes the similarity between statutory and court collection procedures, and applies limitation laws irrespective of the remedial steps taken to collect a tax debt.
[32] Limitation provisions have the effect of requiring a cause of action to be merged in a judgment which is obtained in a proceeding commenced within the limitation period. Given that the filing of a certificate is the mechanism which the Act provides for the Minister to obtain the "same effect" as a judgment, it seems to me that the filing of a certificate must protect the Minister's right to collect a tax debt whether by statutory or court collection procedures.
[33] Subsection 224(1) of the Act allows the issuance of a requirement to pay where the tax debtor is "liable to make a payment under this Act". The tax debtor is not so liable where the Minister is statute-barred from enforcing collection. Where, however, the Minister has preserved the debt by filing a certificate, which has the same effect as a judgment, the debt is not extinguished, the debtor remains liable to pay monies owing under the Act (tax, penalties, interest and the like) and a requirement to pay may be issued.
[34] Moreover, section 3 of the Limitation Act would permit an action to be brought on the certificate, which would be deemed to be a judgment of this Court, within six years. That six-year period has not expired so that the debt so certified has not been extinguished.
[35] Second, this interpretation avoids the incongruity that the Minister could enforce the tax debt through a writ of execution, but not through the statutory collection remedies.
[36] Third, this interpretation is consistent with the rationales for limitation legislation because the filing of the certificate brings about certainty and diligence and avoids the need to rely on stale evidence.
[37] It follows, and I have concluded, that the debt has not been extinguished and that the Requirement was properly issued. The application for judicial review will therefore be dismissed.
[38] The Crown seeks the costs of this application. I can see no reason why the costs should not follow the result of the application, as more particularly set out in the following order.
[39] For these reasons:
ORDER
1. The application for judicial review is dismissed.
2. The applicant shall pay to the respondent the costs of this application, to be assessed in accordance with Column III of the table to Tariff B of the Federal Court Rules, 1998.
"Eleanor R. Dawson"
J.F.C.C.
FEDERAL COURT OF CANADA
Names of Counsel and Solicitors of Record
COURT NO: T-1881-01
STYLE OF CAUSE: GLENN ALEXANDER ROSS
Applicant
- and -
HER MAJESTY THE QUEEN IN RIGHT
OF CANADA
Respondent
DATE OF HEARING: THURSDAY, MARCH 14, 2002
PLACE OF HEARING: VANCOUVER, BRITISH COLUMBIA
REASONS FOR ORDER
AND ORDER BY: DAWSON J.
DATED: WEDNESDAY, APRIL 10, 2002
APPEARANCES BY: Mr. Glenn A. Ross
For the Applicant, on his own behalf
Ms. Donnaree Nygard
For the Respondent
SOLICITORS OF RECORD: Mr. Glenn A. Ross
12135-229th Street
Maple Ridge, British Columbia
V2X 7M9
For the Applicant, on his own behalf
Morris Rosenberg
Deputy Attorney General of Canada
For the Respondent
FEDERAL COURT OF CANADA
Date: 20020410
Docket: T-1881-01
BETWEEN:
GLENN ALEXANDER ROSS
Applicant
- and -
HER MAJESTY THE QUEEN IN RIGHT
OF CANADA
Respondent
REASONS FOR ORDER AND ORDER
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