Approval or denial of your request

Once we have completed our review, we will notify you in writing of our decision. Your request may be approved, partially approved, or denied. If your request is partially approved or denied, our written notification will also advise you what you can do if you do not agree with the CRA decision.

Information specific to requests that are granted

When we have made a decision to grant (approve) your request for relief, please see paragraphs 90 to 99 of Information Circular IC07-1 for information dealing with the rules about:

• reductions to the amount of a refund;
• payments of refund interest;
• the application of a refund to other debts; and
• withholding a refund until outstanding returns are filed.

Right of objection – approved requests

Taxpayers have the right to object in the following two situations:

• If your late, amended, or revoked election is accepted, you can file an objection to dispute the resulting assessment or reassessment. However, the objection is limited to issues related to that election.
• If an original Notice of Assessment is made to allow a refund from filing an income tax return beyond the normal three-year period for an individual (other than a trust) or a testamentary, the normal objection procedures apply.

Second administrative review

If you believe that the CRA did not properly exercise its discretion in considering your request, you can ask for a second review. You may request a second review by writing to the address provided in the decision letter you received in reply to your first request for relief, or by writing to the Intake Centre responsible for your province or territory of residence.

A second review request requires the following:

• the reasons why you disagree with the CRA's decision, e.g., not all information was considered, certain facts or details were missing or misinterpreted or not considered in their proper context; and
• any relevant new documents, new facts, or correspondence.

To maintain impartiality and transparency, the second review will not be conducted by the CRA official involved in the first review and decision.

The CRA may still uphold its previous decision following a second review of your request for relief. If you feel that the discretion was not properly exercised during the second review, you can apply to the Federal Court for a judicial review of the CRA decision within 30 days of the date you received the CRA second review decision.

Related topics

• Cancel or waive penalties or interest
• Late, amended, or revoked elections
• Refund or reduce the amount payable beyond the normal three-year period

Date modified:

2013-05-07