CRA revises its memorandum on objections

Points made in a significantly revised version of GST/HST Memorandum 31-0, Objections and Appeals issued back in May 2024 included:

  • A notice of assessment can cover multiple reporting periods and, indeed, a “Notice of Assessment generally will cover an entire audit period” (suggesting that a multiplicity of objections need not be filed where CRA shows adjustments on a month-by-month basis attached to a global assessment notice).
  • On an objection “the person is informed of discussions held between the appeals officer and the assessing area about the disputed assessment.”
  • An objection can result in an “upward reassessment” (e.g., increasing the tax from what was objected to).

Neal Armstrong. Summaries of GST/HST Memorandum 31-0, Objections and Appeals, May 2024 under ETA s. 300(2), s. 301(1.1), s. 301(1.5) and s. 301(3).