How to File a CRA Objection: Step-by-Step
Disagree with your Notice of Assessment or Reassessment? You have the legal right to file a formal Notice of Objection with CRA. This guide covers the 90-day deadline, how to file for T1, T2 and GST/HST, what to include, complexity levels, processing times and when to escalate to Tax Court. Written by a licensed Ontario CPA.
What Is a Notice of Objection?
A Notice of Objection is a formal legal document filed with the CRA Appeals Division when you disagree with a Notice of Assessment or Notice of Reassessment. It is the first step in the tax dispute process and it is your legal right under Sections 165 (Income Tax Act) and 301 (Excise Tax Act). Filing an objection tells CRA that you dispute their assessment and triggers an independent review by a CRA Appeals officer who was not involved in the original assessment or audit.
An objection is not a complaint, not a phone call and not a letter to your tax centre. It is a formal filing with strict deadlines. Missing the deadline forfeits your right to dispute the assessment through the normal process.
| Objection Type | Legislative Authority | Filing Deadline |
|---|---|---|
| T1 (personal income tax) | Section 165(1) of the Income Tax Act | 90 days from the date on the Notice of Assessment or Reassessment, OR one year from the filing deadline for the tax year (whichever is later) |
| T2 (corporate income tax) | Section 165(1) of the Income Tax Act | 90 days from the date on the Notice of Assessment or Reassessment |
| GST/HST | Section 301(1.1) of the Excise Tax Act | 90 days from the date on the Notice of Assessment |
| CPP/EI (employment insurance, pensionable earnings) | Section 92 of the Employment Insurance Act / Section 27.1 of the Canada Pension Plan | 90 days from the date the ruling or assessment was communicated |
The 90-Day Deadline Is Absolute: If you miss the 90-day filing window, you must apply for a time extension under Section 166.1 (Income Tax Act) or Section 303 (Excise Tax Act). CRA may grant the extension if you apply within one year of the deadline, demonstrate that you intended to object within the original 90 days and provide a reasonable explanation for the delay. After one year plus 90 days, the right to object is lost entirely and the assessment becomes final. There is no further administrative remedy. The only remaining option is a Tax Court application under Section 166.2, which requires legal representation.
How to File a CRA Objection: 8 Steps
Review the Assessment
Read the Notice of Assessment or Reassessment line by line. Identify exactly which lines CRA changed and the dollar amount of each adjustment.
Check the Deadline
Note the date on the Notice. You have 90 days from that date. Mark the deadline in your calendar immediately. Do not wait.
Gather Evidence
Collect receipts, invoices, bank statements, contracts, T-slips and any other documentation that supports your position on each disputed item.
Write Your Grounds
For each disputed item, write a clear statement of why you disagree, the facts that support your position and the relevant section of the law.
Choose Filing Method
File online through CRA My Account (T1), My Business Account (T2/HST), or by mailing Form T400A to the Chief of Appeals at your tax centre.
File Before the Deadline
Submit the objection. If filing by mail, send it by registered mail or courier and keep proof of delivery. The postmark date is the filing date.
Wait for Assignment
CRA assigns an Appeals officer to your file. Processing time depends on complexity: 4 months (low) to 2+ years (high). CRA will contact you.
Negotiate or Escalate
The Appeals officer reviews your file independently. You may resolve the dispute at this stage. If not, you can escalate to Tax Court of Canada.
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How to File: Online, Mail or Through a CPA
| Filing Method | How | Best For |
|---|---|---|
| CRA My Account (T1 personal) | Log in to My Account > Register My Formal Dispute > Select the tax year and assessment > Enter your grounds for objection | Simple T1 objections (denied credits, missed deductions). Immediate confirmation of receipt. |
| CRA My Business Account (T2/HST) | Log in to My Business Account > Register My Formal Dispute > Select the account and period > Enter your grounds | Corporate T2 and GST/HST objections. Immediate confirmation. |
| Form T400A by mail | Complete Form T400A (Objection - Income Tax Act) and mail it to the Chief of Appeals at the tax centre that issued the assessment. | Complex objections where you need to attach supporting documents. Send by registered mail for proof of delivery. |
| Through a CPA or tax professional | Your CPA prepares the objection, writes the legal grounds, attaches all supporting evidence and files on your behalf using Form T400A or online. | Any objection over $5,000. Complex reassessments, gross negligence penalties, business audits and multi-year disputes. |
Online Filing Provides Instant Confirmation: When you file through CRA My Account or My Business Account, you receive an immediate confirmation number proving the objection was received. This is the safest method for meeting the 90-day deadline. If you file by mail, use registered mail or courier and keep the tracking number as proof of delivery. CRA counts the postmark date, not the date they receive it, as the filing date.
What to Include in Your Notice of Objection
The quality of your objection determines the outcome. A one-line objection stating "I disagree" gives the Appeals officer nothing to work with. A detailed, evidence-supported objection with clear legal grounds gets results.
| Element | What to Write | Why It Matters |
|---|---|---|
| Identification | Your full legal name, SIN or Business Number, the tax year(s) in dispute and the date on the Notice of Assessment or Reassessment | CRA must match your objection to the correct file. Missing identification delays assignment. |
| Specific items in dispute | List each line item CRA adjusted: the amount, the CRA adjustment and what you believe the correct amount should be | The Appeals officer only reviews items you specifically dispute. If you do not mention an adjustment, it is accepted. |
| Facts supporting your position | For each disputed item, state the facts: what happened, when, what you paid, what you received, how the transaction was structured and why it supports your position | Facts are the foundation of your objection. The Appeals officer weighs your facts against CRA's audit findings. |
| Legal basis (sections of the Act) | Reference the specific sections of the Income Tax Act, Excise Tax Act or related legislation that support your claim | CRA Appeals officers are trained in the law. Citing the correct section demonstrates that your position has legal merit, not just a personal opinion. |
| Supporting documents | Attach copies (never originals) of receipts, invoices, bank statements, contracts, T-slips, correspondence and any expert opinions that support your position | An unsupported claim is denied. CRA needs documentary evidence to reverse an assessment. Provide everything the Appeals officer needs in the initial filing. |
| Dollar amount of the dispute | State the total tax, penalty and interest you are disputing | The dollar amount determines how CRA prioritises and categorises the file. |
Include Everything in the First Filing: The Appeals officer's review is based on what you submit. Sending a bare objection and planning to provide details later is a poor strategy. The officer may make a decision before you submit additional information, or your file may be deprioritised. Prepare a complete package with grounds, facts, law and evidence before filing. We prepare a full objection brief for every client before submission.
CRA Objection Complexity Levels and Processing Times
CRA classifies every objection into one of three complexity levels. The complexity determines how long it takes to process and which Appeals officer is assigned. Understanding your complexity level sets realistic expectations for the timeline.
| Complexity Level | Average Processing Time | Typical Issues | % of All Objections |
|---|---|---|---|
| Low | 126 days (approximately 4 months) | Denied personal credits (medical, disability, tuition), Canada Child Benefit adjustments, simple T1 deductions, RRSP overcontributions | Majority of objections |
| Medium | 323 days (approximately 10 to 12 months) | Business expense denials, T2 reassessments for small and mid-size corporations, CCA disputes, shareholder loan assessments, partnership income allocations | Significant portion |
| High | 690+ days (approximately 2+ years) | Large corporate audits, international transfer pricing, GAAR (General Anti-Avoidance Rule) assessments, tax avoidance schemes, multi-year restructurings | 2 to 3% of all objections |
Interest Continues During the Objection: Filing an objection does not stop interest from accruing on the disputed balance. CRA charges 8% compound daily interest on the balance owing from the original filing deadline through the entire objection period. If you win the objection, CRA refunds the tax and interest. If you lose, you owe the full balance plus all interest accumulated during the dispute. On a $50,000 dispute that takes 12 months at the Appeals level, approximately $4,000 in additional interest accrues. Consider paying the disputed amount and requesting a refund if the objection succeeds, to stop the interest clock.
What Happens After You File a CRA Objection
| Stage | What Happens | Timeline |
|---|---|---|
| Acknowledgement | CRA sends a letter confirming receipt of your objection and assigning a file number. | 2 to 8 weeks after filing |
| Assignment to Appeals officer | An independent Appeals officer (not involved in the original audit) is assigned to your file. | Varies by complexity and backlog |
| Review and contact | The Appeals officer reviews your objection, supporting documents and the auditor's working papers. They may contact you to request additional information or discuss a settlement. | Ongoing throughout the process |
| Decision issued | CRA issues a Notice of Confirmation (they uphold the assessment), a Notice of Reassessment (they change the assessment partially or fully in your favour), or the assessment is vacated entirely. | 126 to 690+ days depending on complexity |
| Tax Court option (if you disagree with the decision) | If CRA confirms the assessment and you still disagree, you have 90 days from the Notice of Confirmation to file an appeal with the Tax Court of Canada. | 90 days from CRA's decision to file the Tax Court appeal |
When to Escalate to Tax Court of Canada
| Situation | Action | Key Details |
|---|---|---|
| CRA confirms the assessment after your objection | File a Tax Court appeal within 90 days of the Notice of Confirmation | The Tax Court is an independent court. CRA must prove their assessment is correct. You present your case to a judge. |
| CRA has not processed your objection after 90 days | You can file a Tax Court appeal directly (Section 169(1)) | If CRA has not responded to your objection within 90 days of filing, you have the right to bypass the Appeals process and go directly to Tax Court. |
| Informal Procedure (disputes under $25,000 federal tax or $50,000 income/loss) | File under the Informal Procedure for a faster, less formal hearing | No lawyer required. Simplified rules of evidence. Decision typically within 6 to 12 months. CRA cannot claim costs against you. |
| General Procedure (disputes over $25,000 federal tax) | File under the General Procedure for a full hearing | Formal litigation. Legal representation strongly recommended. Full rules of evidence and discovery apply. Costs may be awarded. |
The 90-Day Tax Court Deadline Is Also Absolute: If CRA issues a Notice of Confirmation and you do not file a Tax Court appeal within 90 days, the assessment becomes final. There is no further recourse. The 90-day clock starts on the date of the Notice of Confirmation, not the date you receive it. If CRA mails the Confirmation and you receive it 10 days later, you have already lost 10 days. Act immediately upon receiving any CRA Confirmation.
Does Filing an Objection Stop CRA Collections?
| Tax Type | Collections Held During Objection? | Important Exception |
|---|---|---|
| T1 (personal income tax) | Yes. CRA cannot take collection action on the disputed amount while the objection is pending. | CRA can still offset refunds and government payments (GST credit, CCB, OTB) against the disputed balance. |
| T2 (corporate income tax) | Yes. Same collection hold as T1 for the disputed amount. | CRA can still collect undisputed amounts. Only the specific items objected to are held. |
| GST/HST | No. CRA can collect the full GST/HST balance during the objection period. There is no automatic collection hold for HST objections. | You can request a collection hold by contacting CRA Collections, but it is discretionary, not automatic. |
| Payroll source deductions | No. CRA can collect payroll source deductions during the objection. Trust amounts are not subject to a collection hold. | Director liability under Section 227.1 can be assessed and collected during the objection period. |
GST/HST Objections Do Not Stop Collections: This catches many business owners off guard. When you file a T1 or T2 objection, CRA cannot garnish your wages, freeze your bank account or register a property lien on the disputed amount. When you file a GST/HST objection, CRA can take full collection action immediately. If you are disputing a large GST/HST assessment, contact CRA Collections to request a discretionary hold or consider paying the disputed amount and requesting a refund if the objection succeeds.
Facing a CRA Assessment? We File the Objection for You.
We prepare the grounds, gather the evidence, file on time and communicate with CRA Appeals on your behalf.
10 Common CRA Objection Mistakes
| # | Mistake | Consequence |
|---|---|---|
| 1 | Missing the 90-day deadline | Right to object is lost. Must apply for an extension within one year. After one year + 90 days, the assessment is final. |
| 2 | Filing a one-line objection ("I disagree") | Appeals officer has nothing to work with. File is deprioritised. Likely confirmation of the original assessment. |
| 3 | Not listing all disputed items specifically | The Appeals officer only reviews items you mention. Unlisted adjustments are accepted by default. |
| 4 | Not attaching supporting documents | An unsupported claim is denied. CRA needs evidence to reverse an assessment. Verbal arguments alone fail. |
| 5 | Confusing an objection with a Taxpayer Relief application (RC4288) | RC4288 requests waiver of penalties and interest. An objection disputes the underlying tax. They are different processes with different outcomes. |
| 6 | Assuming the objection stops interest | Interest accrues at 8% daily compound throughout the objection period. A 12-month objection on $50,000 adds approximately $4,000 in interest. |
| 7 | Assuming a GST/HST objection stops collections | CRA can garnish, freeze and lien during a GST/HST objection. No automatic hold applies. |
| 8 | Not responding to the Appeals officer's requests for information | The officer decides based on what they have. Non-response typically results in confirmation of the assessment. |
| 9 | Missing the 90-day Tax Court deadline after a Notice of Confirmation | The assessment becomes final. No further recourse. The clock starts on the date of the Confirmation, not when you receive it. |
| 10 | Not hiring a CPA for objections over $5,000 | A professional objection with legal grounds, cited sections and complete evidence has a significantly higher success rate than a self-filed objection. |
CRA Objection Filing Checklist
- Confirm the date on your Notice of Assessment or Reassessment and calculate the 90-day deadline
- Identify every specific line item CRA adjusted and the dollar amount of each adjustment
- Gather all supporting documents: receipts, invoices, bank statements, contracts, T-slips, correspondence
- Write detailed grounds for each disputed item: facts, legal basis (section of the Act) and the correct amount
- State the total tax, penalty and interest in dispute
- Include your full legal name, SIN or Business Number and the tax year(s)
- Choose your filing method: CRA My Account (T1), My Business Account (T2/HST) or Form T400A by mail
- If filing by mail, send by registered mail or courier and keep proof of delivery
- Keep a complete copy of everything you submit
- Note the confirmation number (online) or tracking number (mail) and store it with your tax records
- Calendar the 90-day Tax Court deadline in case CRA issues a Notice of Confirmation
- Consider engaging a CPA for any objection involving more than $5,000 in disputed tax
CRA Objection Filing: FREE for Tax Clients. $400 Flat Fee Standalone.
We prepare the full objection brief, file with CRA and handle all communication with the Appeals officer.
Frequently Asked Questions: CRA Objections
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