CRA Tax Objections

After a reassessment has been issued by CRA, you have 90 days from the date of the reassessment to file a Notice of Objection. If you have only been issued an assessment, you generally have until April 30 of the next year to file an Objection.

If you miss that 90 day period or April 30 period, you have one year to file an extension of time to file a Notice of Objection and explain why you didn't file an Objection within time.

A Notice of Objection is to include the facts and reasons why you disagree with the assessment or reassessment.

The Appeals Division of CRA is mandated to independently review Objections. Keep in mind, however, that the Appeals Division is still comprised of officials of CRA.

Through the Objection process, you are entitled to receive a copy of CRA Reports, working papers and other documents relied on by the auditor.

The Appeals Division job is to review the auditor's position and facts in support, as well as to review the taxpayer's position, submissions and documents. It is rare for the Appeals officer to actually meet with the taxpayer or their counsel.

The Appeals Division will:

  • Agree with the auditor and confirm the (re)assessment
  • Agree partly with the auditor and partly with the taxpayer and vary the (re)assessment, or
  • Agree completely with the taxpayer and vacate the (re)assessment. CRA may ask a taxpayer, in the second scenario in particular, to sign a "waiver". "Waivers" have significant legal consequences and should be discussed with a lawyer to fully understand their scope.

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