Among the commentators that have called the distinction into question—indeed, discarded it completely—is the Supreme Court of Canada, in the leading case of Beals v. Saldanha, [2003] 3 S.C.R. 416 at para. 51:

The historic description of and the distinction between intrinsic and extrinsic fraud are of no apparent value and, because of their ability to both complicate and confuse, should be discontinued. It is simpler to say that fraud going to jurisdiction can always be raised before a domestic court to challenge the judgment. On the other hand, the merits of a foreign judgment can be challenged for fraud only where the allegations are new and not the subject of prior adjudication. Where material facts not previously discoverable arise that potentially challenge the evidence that was before the foreign court, the domestic court can decline recognition of the judgment.

Best regards,

Alex