A taxpayer may wish to re-object if its initial objection results in a varied reassessment

Where CRA responds to an objection by reassessing to vary the previous reassessment (thereby nullifying it), the taxpayer, rather than appealing the varied reassessment to the Tax Court under s. 165(7), can choose to re-object (unless it is a nil reassessment.) Where there is a re-objection, the CRA policy (per 3.3.2.8 of the Audit Manual) is to assign the file to the same appeals officer.

Taxpayers (including large corporations by virtue of s. 165(1.1)) have the right to address new issues raised in the varied reassessment.

Neal Armstrong. Summary of Robert Celac, “Re-Objecting After a Varied Reassessment,” Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 3 under s. 165(7).