CRA notice of objection help for Canadian businesses

A notice of objection is the formal way to dispute a CRA assessment or reassessment. It sends your file to CRA's Appeals Branch, which reviews it independently of the auditor and can confirm, change or cancel the assessment. For income tax it's filed online or with Form T400A, and for GST/HST online or with Form GST159.

Yes. Appeals can cancel or reduce a reassessment when the facts, the law or the calculations don't support it. Common examples are input tax credits denied over paperwork that other records cover, bank deposits counted as income that were never income, and penalties CRA can't prove.

For corporations, GST/HST and payroll assessments, 90 days after the date CRA sent the notice. Individuals have until the later of 90 days after the notice or one year after their filing due date for that tax year. Count from the date printed on the notice, not the day it arrived.

Online through My Business Account, My Account or Represent a Client, using the formal dispute option, or by mail using Form T400A for income tax or Form GST159 for GST/HST. Set out each issue you disagree with, the facts and reasons, and attach the documents that support your position.

Each adjustment you disagree with, the result you're asking for, the relevant facts, the reasons under the law, and the supporting documents. Objections that only say you disagree rarely succeed. Large corporations must also describe each issue and the amount of relief sought, and are limited to those issues if the file goes to court.

Often, yes. You can apply for an extension of time up to one year after the objection deadline. You'll need to show that you intended to object on time or couldn't act, that you applied as soon as circumstances allowed, and that granting it is just and equitable. File the objection together with the request.

For income tax, CRA generally can't collect the disputed amount until 90 days after Appeals decides, although large corporations pay half and payroll withholdings aren't postponed. GST/HST is payable right away, and CRA can collect it while you object unless it agrees to postpone collection or accepts security. Interest runs either way, so some businesses pay and object at the same time.

CRA publishes average processing times every month. Recently, simpler income tax objections have averaged around four months, and medium-complexity files, which include most business disputes, around a year. If Appeals hasn't decided within 90 days for income tax or 180 days for GST/HST, you can take the matter to the Tax Court instead.

A proposal letter comes during the audit and sets out changes CRA intends to make. You respond to it, usually within 30 days, but you can't object to it. A notice of reassessment is the decision itself, and it's the document that starts the objection clock.

CRA can normally reassess within three years of the original notice for individuals and Canadian-controlled private corporations, and four years for other corporations. For GST/HST, the limit is generally four years from when the return was due or filed. After that, CRA must show a misrepresentation due to carelessness, neglect or wilful default, or fraud, and the burden of proof is on CRA.

Resending them to the same area rarely helps. A formal objection moves the file to an appeals officer who reviews it independently. Attach the documents and explain which adjustment each one answers. If the problem is a payment CRA didn't apply, ask for a payment search first, since that's usually faster.

Yes. An objection can target the tax, the penalty, or both. For a gross negligence penalty, CRA has to prove the facts that justify it. Penalties and interest can also be addressed through a separate taxpayer relief request on Form RC4288.

It can. If the year is still within the normal reassessment period, CRA can look at other items while reviewing the file. That's why we check the file for exposure before anything is filed.

You have 90 days from the notice of confirmation to appeal to the Tax Court of Canada. Smaller disputes can use the informal procedure, which is simpler and has no filing fee. Larger or more complex appeals use the general procedure, where a corporation is normally represented by a lawyer.

Most objections turn on facts, records and calculations, which is accounting work, so a CPA with audit experience is often the practical choice at the objection stage. If a file is headed for the Tax Court's general procedure or there's any criminal exposure, a tax lawyer should be involved. Communications with a lawyer can be privileged, while communications with an accountant generally aren't. We work alongside counsel when a file needs it.

Right away you get the basics: what the letter means, whether you can object, your deadline and extension window, the amount, how collections and interest work, how to file, and links to the official CRA forms. If you want Brookside CPA to review it, add your name, email and phone. The page creates one PDF with your details, the report and your letter, then opens an email to Brookside CPA with everything filled in. You attach the file and send, and a booking window opens for a free 15-minute call.

Yes. Your letter is read on your own device and is never uploaded to us or anyone else. If you ask for a review, the page creates your review file on your device and you choose to email it to us. Everything you share is kept confidential and used only to review your notice and contact you.