At a prior Roundtable, CRA indicated that on receipt of a builder's objection to a reassessment under s. 191(3), where the issue is the FMV of the property, the Appeals Branch will automatically refer to, or otherwise involve, a different appraiser than the particular appraiser who performed the valuation for CRA Audit.
When asked for confirmation that CRA Appeals Officers have been made aware that, on an appeal, the valuation issue should be referred to a second appraiser, rather than the original appraiser, CRA described its educational and review processes in this regard.
When asked whether “the Appeals Officer be required to obtain a full second appraisal of the property from a different appraiser in the CRA Appraisal Group,” CRA responded:
Where the Objector provides a new valuation or appraisal report at the Objection Stage, the Appeals Officer in discussion with their Team Leader will request assistance from the Regional Real Estate Appraisal section. They may assign a valuator or appraiser, other than the individual who prepared the value conclusion at the audit stage, who will perform the review and prepare the appropriate report to ensure impartiality and objectivity. If the new report includes additional information that was not previously available to the CRA valuator or appraiser, the existing CRA report will be updated.
When asked whether “neither (a) the original CRA Real Estate Appraiser nor (b) any appraiser within the same group/office of the initial CRA appraiser will be involved or provide input respecting the objection or appeal and that if CRA’s Appeal Division requires input in respect of the GST-registrant’s Objection or Appeal, such advice will be provided by a wholly independent CRA appraiser from a different CRA Real Estate Appraisal Group/Office, without contact with … the initial CRA appraiser,” CRA responded only by indicating that its appraisers were required under their professional standards to be impartial and unbiased.
