A prescrição intercorrente na execução fiscal na visão do STJ: notas críticas e perspectivas com a Lei nº 14.195/2021

This paper analyzes the binding interpretation given by the Superior Court of Justice in regard to the initial term and the way of counting the suspension and intercurrent limitation period regulated by art. 40 of the Law nº 6.830/80, under a critical perspective guided by the light of the fundamental guarantees and the chronic ineffectiveness of tax enforcement in Brazil. At the end, a few new trends brought by the recent reform done by the Law nº 14.195/2021 on the Civil Procedure Code will be pointed out.