Global Minimum Tax Act — G-3.3 127
Certificates 127 (1) Any amount payable by a person (referred to in this section as the “debtor”) under this Act that has not been paid as and when required under this Act may be certified by the Minister as an amount payable by the debtor. Registration in court (2) On production to the Federal Court, a certificate made under subsection (1) in respect of a debtor is to be registered in the Court and, when so registered, has the same effect, and all proceedings may be taken on the certificate, as if it were a judgment obtained in the Court against the debtor for a debt in the amount certified plus interest on the amount as provided under this Act to the day of payment and, for the purposes of those proceedings, the certificate is deemed to be a judgment of the Court against the debtor for a debt due to His Majesty in right of Canada and enforceable as such. Costs (3) All reasonable costs and charges incurred or paid for the registration in the Federal Court of a certificate made under subsection (1), or in respect of any proceedings taken to collect the amount certified, are recoverable in the same manner as if they had been included in the amount certified in the certificate when it was registered. Charge on property (4) A document issued by the Federal Court that is evidence of a registered certificate in respect of a debtor, a writ of that Court issued in accordance with the certificate or any notification of the document or writ (which document, writ or notification is referred to in this section 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, or for civil law any right in, such property, held by the debtor, in the same manner as a document that is evidence of (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 His Majesty in right of the province may be filed, registered or otherwise recorded in accordance with the law of the province to create a charge, lien or priority on, or a binding interest in, the property or interest. Creation of charge (5) If a memorial has been filed, registered or otherwise recorded under subsection (4), (a) a charge, lien or priority is created on, or a binding interest is created in, property in the province, or any interest in, or for civil law any right in, such property, held by the debtor, or (b) such property, or interest or right in the property, is otherwise bound in the same manner and to the same extent as if the memorial were a document that is evidence of a judgment referred to in paragraph (4)(a) or an amount referred to in paragraph (4)(b), and the charge, lien, priority or binding interest created is subordinate to any charge, lien, priority or binding interest in respect of which all steps necessary to make it effective against other creditors were taken before the day on which the memorial was filed, registered or otherwise recorded. Proceedings in respect of memorial (6) If a memorial is filed, registered or otherwise recorded in a province under subsection (4), proceedings may be taken in the province in respect of the memorial, including proceedings (a) to enforce payment of the amount evidenced by the memorial, interest on the amount and all costs and charges paid or incurred in respect of (i) the filing, registration or other recording of the memorial, and (ii) proceedings taken to collect the amount, (b) to renew or otherwise prolong the effectiveness of the filing, registration or other recording of the memorial, (c) to cancel or withdraw the memorial wholly or in respect of any of the property, or interests or rights, affected by the memorial, or (d) to postpone the effectiveness of the filing, registration or other recording of the memorial in favour of any right, charg