Can I file an income tax objection?

You or your authorized representative can file an income tax objection if you have received any of the following:

• Notice of Assessment;
• Notice of Reassessment;
• Notice of Determination; or
• Notice of Redetermination.

You cannot file an objection to dispute the following:

• a Statement of Account , or
• a proposal letter from an auditor.

You are required to clearly explain why you disagree with the assessment or determination and also include all of the relevant facts and reasons.

The time limits for filing an objection are as follows:

If you are an individual:

• the time limit for filing an objection is whichever of the following two dates is later:
  • one year after the date of the filing deadline for the return (April 30 or June 15), or
  • the day that is 90 days after the day of sending the Notice of Assessment (the date of the notice or notification).

If you are a business or for assessments of taxes in respect of over-contributions to a registered retirement savings plan (RRSP) or tax-free savings account (TFSA):

• the time limit to file an objection is within 90 days of the day we sent the Notice of Assessment or Reassessment (the date of the notice or notification).

For information about RRSP excess contributions, go to www.cra.gc.ca/rrsp.

For information about TFSA excess contributions, go to www.cra.gc.ca/tfsa.

What if my objection is past the time limit?

If you did not file your objection on time because you attempted to have your change made by contacting the originating CRA office or because of circumstances beyond your control, you can apply for a time extension to file an objection. You can apply by writing to the Chief of Appeals at your Appeals Intake Centre (see Appendix B of pamphlet P148), or by using the My Account or My Business Account online services. You have to explain why you did not file your objection on time along with the facts and reasons of your objection.

The application for a time extension to file an objection must be made within one year after the expiration of the time limit to file an objection.

How do I file an income tax objection?

Here is what you provide when you file an income tax objection:

• clear details of the issue(s) you are disputing, for example: I received a reassessment and my expenses were reduced because my receipts were disallowed. I believe that my receipts qualify as proof of my expenses because (insert reasons), and
• any documentation to support your claim.

For an example of an income tax objection letter, see Appendix A of pamphlet P148 Resolving your dispute: Objection and appeal rights under the Income Tax Act.

You will find the steps to follow to file an objection and processing timeframes below. It is important to always provide all relevant information to CRA to allow for a complete consideration of the issue, at the assessing, audit, and objection stages.

You or your authorized representative can file an objection in one of the following ways:

• online at My Account by selecting "Register my formal dispute";
• online at My Business Account by selecting "Register a formal dispute (Notice of Objection)" for “Corporations”;
• online at Represent a Client; or
• by mail, using Form T400A, Objection – Income Tax Act, or in writing to the chief of appeals at your Appeals Intake Centre (see Appendix B of pamphlet P148).

In all cases, you should clearly explain why you disagree and include all relevant facts, reasons, and supporting documents.

You or your authorized representative can submit supporting documents online at My Account, My Business Account, or Represent a Client, by selecting the “Submit documents” service.

For more information on the Submit Documents online service, go to Submit documents online.

How long will my objection take?

The time it takes to complete the review of an objection varies.

Factors that influence the time it takes include:

• the complexity of the issue, and
• delays caused by not submitting all the facts, reasons and documentation.

Your objection may be assigned sooner, if your submission is clear and complete.

Are there different levels of complexity for objections?

Low complexity objections:

These objections often involve issues such as: individual tax credits, personal deductions, Canada Child Benefit, and Disability Tax Credit.

Medium complexity objections:

These objections often involve issues such as: business expenses and more complex T1 issues.

High complexity objections:

These objections involve large corporations, complex business transactions, international transfer pricing, and General Anti-Avoidance Rule assessments.

Scientific Research and Experimental Development (SR&ED) objections:

Consulting with specialists is often required to resolve these objections.

Tax avoidance schemes:

For information on tax avoidance see Tax Avoidance and Cracking down on offshore tax evasion and aggressive tax avoidance.

When will an appeals officer look at my objection?

Low and medium complexity objections:
For the objection resolution timelines for low and medium complexity objections, refer to the Objections Assignment and Resolution Timelines table at the top of this page.

High complexity, Scientific Research and Experimental Development (SR&ED) objections and Tax avoidance schemes:
Due to the complex nature of the issues involved, at this time we cannot provide a timeframe for the resolution of these objections.

How can I have my objection resolved faster?

There is a lot you can do to speed up the processing of your objection. To have your objection resolved faster:

• ensure that all explanations and documentation are provided as early in the process as possible
• ensure that your concerns are fully explained and supported
• submit the objection electronically using My Account, My Business Account or Represent a Client.

What causes delays during the objection review?

Your objection may take longer if:

• it is not clear what you are objecting to
• you do not provide the facts, reasons, and supporting documentation with your objection
• the appeals officer needs to consult other CRA tax specialists
• there is an appeal to the courts that may cause your objection to be held in abeyance, pending the outcome
• if you do not submit your objection electronically using My Account, My Business Account or Represent a Client.

You will be notified if more information is required or your objection is delayed.

What do I do if I don’t agree with the decision made in regards to my objection?

Once you receive CRA's decision resulting from an objection, you can appeal your assessment or determination to the Tax Court of Canada, either under the Informal Procedure or the General Procedure. The time limit for filing an appeal is 90 days from the date on the notice. The Tax Court procedures are explained in publication P148, Resolving Your Dispute: Objections and Appeal Rights under the Income Tax Act. You can appeal the Tax Court's decision to the Federal Court of Appeal, and a judgment of the Federal Court of Appeal can be further challenged before the Supreme Court of Canada, with the Court's permission.

Time Extension – Notice of Appeal

You can apply for an extension to file your appeal by making an application to the Tax Court of Canada. Explain why you cannot or did not file your appeal on time.
Apply as soon as possible, but the application must be made within one year after the expiration of the time limit to file an appeal.

Amounts owing that are under a formal review

In most cases, you do not have to pay income tax amounts that are in dispute until the CRA has completed its formal review or, if you have filed an appeal, until the Tax Court of Canada issues its decision or you withdraw your appeal. In addition, if you file an objection and have previously paid an amount toward an assessment or reassessment, you may ask us to repay the amount you paid that is in dispute. If you are entitled to a repayment, we will first apply the amount to reduce or clear any other amounts you owe that are not in dispute. We will refund the remainder.

It is important to note that interest charges apply during any period that an amount in dispute is not paid/refunded. You can pay all or part of the amount, and you will receive a refund with interest if you are successful.

The Minister may grant relief from penalties or interest in certain circumstances. For more information, visit Cancel or waive penalties or interest.

While an application for taxpayer relief from interest or penalties is under consideration, collection action will continue on any undisputed amount and the amount is due and payable. For more information on collections, visit When you owe money-collections at the CRA.

After the decision -- Collection action resumes on amounts owed

Once the decision rendered on the objection has been issued, any amounts owed that are no longer under dispute would be payable, including taxes, penalties, and interest where applicable. Collection action following an objection, is usually delayed until 90 days after we send our decision to you.

Who do I contact if I have questions about the status of my objection and I have not yet been contacted by an appeals officer?

If you have not yet been contacted by an Appeals Officer, or do not have the officer's contact information, you may contact one of the Intake Centres:

Eastern Intake Centre

Toll Free Public Enquiries Line: 1-866-242-3161 (English), 1-866-276-0969 (French)
Local Public Enquiries Line: 705-671-0238 (English), 705-677-7764 (French)
Fax: 1-866-443-4955, Local: 705-671-0388

Western Intake Centre

Public Enquiries Line: 1-800-959-5513
Fax: 1-866-489-6832, Local: 604-587-2672

Publication

• P148, Resolving Your Dispute: Objections and Appeal Rights under the Income Tax Act